The United States v. William Fowler, et.

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G.R. No. L-496, 31 December 1902

Facts:
On August 12, 1901, a crime of theft was committed on board the transport Lawton, then navigating on the
high seas. The two defendants have been accused of stealing bottles of champagne owned by Julian Lindsay and
said property formed part of the vessel’s cargo. The accused, having been brought before the Court of First Instance
in Manila, presented an objection that such court has no jurisdiction to try the crime charged against them, since it
was committed on the high seas and not within the 3-mile limit to which the court’s jurisdiction extends.
The prosecuting attorney opposed such contention asserting that the court has original jurisdiction in all
criminal cases in which the penalty exceeds six months of imprisonment or a fine of $100, and as ordered by the
Military Governor and the Civil Commission admiralty, said court is accorded the jurisdiction over all crimes
committed on board vessels flying the US flag. Several laws were likewise cited to support such contention of the
prosecution.
However, on September 14, 1901, the judge held that the court was without jurisdiction to hear and
determine such crime of theft committed on the high seas. Against this order, the prosecuting attorney herein brought
this appeal.

Issue: Whether or not the Court of First Instance of Manila has the jurisdiction over the crime of theft committed on
board a foreign vessel on the high seas?

Ruling:
No. The Court of First Instance has no jurisdiction over the crime of theft committed on board a foreign
vessel on the high seas.
Act No. 136 of the organic law, as well as Act No. 186 passed by the Civil Commission which repealed Act
No. 76, as cited by the prosecution on their appeal, do not expressly confer authority upon this court to take
cognizance of all crimes committed on board vessels on the high seas. Instead, this Court cited Act 400 as the law
applicable to the case at hand. This law states that “all crimes and offenses committed on the high seas or beyond
the jurisdiction of any country, or within the navigable waters of the Philippine Archipelago, on board a ship or water
craft of any kind registered or licensed in the Philippine Islands in accordance with the laws thereof.” Further, Act 400
defined the jurisdiction of the Courts of First Instance in criminal cases for crimes committed on boards vessels
registered or licensed in the Philippine Islands.
The transport Lawton where the crime of theft was committed is not within the bounds of ship or water craft
defined in Act 400. Thus, the CFI is of no jurisdiction to take cognizance of the crime of theft which was committed
therein.

The United States v. Ah Sing

G.R. No. L-13005

Facts:
This crime is a violation of Section 4 of Act No. 2381 or the Opium Law . Defendant Ah Sing, bringing with
him eight cans of opium from Saigon, arrived at the port of Cebu on board the foreign steamer on April 25, 1917. On
the same date, authorities on making a search, found the above mentioned eight cans of opium hidden in the ashes
below the boiler of the steamer’s engine. The defendant admitted that the opium was his and purchased it in Saigon
without the intention of importing the prohibited drug into the Philippines Islands. Nonetheless, there was no other
direct or indirect evidence to show that the intention of the accused was to illegally import this opium in the country.
Issue:
Whether or not the crime of illegal importation of opium into the Philippine Islands was proven?
Ruling:
Yes. The crime of illegal importation of opium into the Philippine Islands by the defendant was proven.
As cited in the Federal Courts of the US, the mere act of going into a port, without breaking bulk, is prima
facie evidence of importation. It is further defined that importation is not making entry of goods at the custom house,
but merely bringing them into port then; and the importation is complete before entry to the custom house.
As applied to the Opium Law, it is expressly held that any person unlawfully imports or brings any prohibited
drugs into the Philippine Islands, when the prohibited drug is found under this person’s control on a vessel which has
come direct from a foreign country and is within the jurisdictional limits of the Philippine Islands. In such a case, a
person is guilty of illegal importation of the drug unless contrary circumstances exist or the defense proves otherwise.
It is therefore adjudged that the defendant having brought with him the opium into the Philippine Islands is
prima facie evidence of importation of said prohibited drug, which is an open violation of the Opium Law.
This Court hereby affirmed