The United States vs. H.N.

Bull
G.R. No. L-5270 (1910)

Facts
On December 2, 1908, a steam sailing vessel known as the Standard, a Norwegian vessel, brought to the
Port of Manila six hundred and seventy-seven (677) head of cattle and carabaos, without providing suitable means
for securing the animals in a proper manner while the vessel was in transit.
Some of the animals are tied by means of rings passed through their noses, causing their noses to be cruelly torn.
Also, other animals are not secured in stalls and all are without bedding. Many of the said animals, cruelly
wounded, bruised, and killed, were tossed out of the vessel
Because of this, H.N. Bull, master of the vessel, was accused of neglecting and failing to provide suitable means for
securing the animals while the vessel was in transit.

Issue
Whether the Philippine court’s amendment of Act No. 55 is in violations of certain provisions of the Constitution of
the United States.

Ruling
No, the Supreme Court, through Justice J. Elliot, held that the Philippines did not violate any provisions of
the Constitution of the United States by amending Section 1 of Act No. 55.

Section 1 of Act No. 55 provides that:

“The owners or masters of steam, sailing, or other vessels, carrying or transporting cattle, sheep,
swine, or other animals, from one port in the Philippine Islands, shall carry with them, upon the
vessels carrying such animals, sufficient forage and fresh water to provide for the suitable
sustenance of such animals during the ordinary period occupied by the vessel in passage from
the port of shipment to the port of debarkation, and shall cause such animals to be provided with
adequate forage and fresh water at least once in every twenty-four hours from the time that the
animals are embarked to the time of their final debarkation.”

To which it was amended by Act No. 275 which provides:

“The owners or masters of steam, sailing, or other vessels, carrying or transporting cattle, sheep,
swine, or other animals from one port in the Philippine Islands to another, or from any foreign
port to any port within the Philippine Islands, shall provide suitable means for securing such
animals while in transit so as to avoid all cruelty and unnecessary suffering to the animals, and
suitable and proper facilities for loading and unloading cattle or other animals upon or from
vessels upon which they are transported, without cruelty or unnecessary suffering. It is hereby
made unlawful to load or unload cattle upon or from vessels by swinging them over the side by
means of ropes or chains attached to the thorns.”

The power to regulate foreign commerce is vested in Congress, and by virtue of its power to govern the
territory belonging to the United States, it may regulate foreign commerce with such territory. Act No. 275, an
amendment of Act No. 55 has remained in force since its enactment without annulment or other action by
Congress and must be presumed to have met with its approval.

Therefore, Act No. 55, as amended by Act No. 275, is valid.