Isabela State University | ECHAGUE

College of Criminal Justice Education

ISABELA STATE UNIVERSITY

Echague Main Campus

COLLEGE OF CRIMINAL JUSTICE EDUCATION

-Criminology Program-

COMPARATIVE MODELS IN POLICING

S.Y. 2022-2023

COMPARATIVE MODELS IN POLICING

Reginald C. Sibug, MS CRIM.
1

CHAPTER 1
INTRODUCTION TO COMPARATIVE MODELS IN POLICING
Chapter’s Contents:
A. Introduction
B. Concept of Police
C. Traditional Goals of Policing
D. Ancient Policing System
E. IMPORTANT Terms:
 Comparative Police System
 Comparative Criminal Justice
 Comparative Court System
 Comparative Correctional System
 Comparative Juvenile Justice System
 International Criminal Justice
 Model System
F. Transnational Crimes
LEARNING OBJECTIVES
At the end of the lesson, students should be able
to:
1. Gain general insights about the basic
concept of comparative models in
policing.
2. Explain the concept of police and
differentiate the different concepts
and theories of policing.
3. Enumerate and explain the traditional
goals of Policing
4. Identify and understand the various
ancient policing system around the
world.
5. define and understand the meaning of
Comparative Police System; Criminal
Justice; court system; Correctional
System mean; Juvenile Justice System;
International Criminal Justice; Model
System
6. define and understand the meaning of
Transnational Crime;
7. gain insights on the different
transnational crimes like Drug
trafficking, human trafficking,
Cybercrime, terrorism and Money
laundering.
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
A. INTRODUCTION
The study of comparative models in policing,
comparative police system, comparative criminal justice
and law is a fairly new field and has corresponded with
rising interest in a more established field, comparative
criminology. However, in this chapter, we will present
some issues which will bring you to discover ideas useful
in the conceptualization of successful crime control
policies.
Chapter I contains the salient features of
comparative models in policing. It is focused on the basic
terms and topics covered on this subject prior to the
actual comparison of the police models.
“The modern police service is a varied, multi-layered,
responsive institution working to ensure the safety of
Citizens” – UK Home Office
The role of a modern police organization is laid
down succinctly in the above quote appearing in the
web page of UK Home Office. The first idea that comes to
our mind when we hear the term “Police” is the idea of a
dominant personality who symbolizes the power of the
State and criminal justice administration system. On the
one hand people view police as a protector of civil
liberties and on the other hand police is viewed as a
symbol of brute force of state which oppresses the
legitimate protests with force.
Dictionaries define Police as the governmental
department charged with the regulation and control of
the affairs of a community, now chiefly the department
established to maintain order, enforce the law, and
prevent and detect crime.
Policing is one of the most important of the
functions undertaken by every sovereign government.
For the state machinery, police is an inevitable organ
which would ensure maintenance of law and order, and
also the first link in the criminal justice system. On the
other hand, for common man, police force is a symbol of
brute force of authority and at the same time, the
protector from crime. Police men get a corporate
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College of Criminal Justice Education
identity from the uniform they wear; the common man C. TRADITIONAL GOALS OF POLICING
identifies, distinguishes and awes him on account of the
same uniform. The police systems across the world have The importance of the police in administration of justice
developed on a socio cultural background, and for this can also be shown by studying its five traditional goals
reason alone huge differences exist between these police
which as follows: (1) enforcement of laws; (2)
systems. preservations of the peace; (3) prevention of crimes; (4)
protection of civil rights and liberties; and (5) providing
B. CONCEPT OF “POLICE” other services. The success or failure of the police in
achieving these goals can directly affects the works and
POLICE is the agency of a community or government functions of other pillars. In this regard, police pillar is
that is responsible for enforcing the law, maintaining considered as the BACKBONE of the criminal justice
public order, and preventing and detecting crime. system.
In the very broadest sense, the term POLICE refers to
the internal organization or regulation of the state, the The [1] ENFORCEMENT OF LAWS as one of the
control and regulation of the community or state through traditional goal of police pillar has been considered as
the exercise of the constitutional power of the the prime goal of policing. The police in this regards play
government. a major role in fashioning and implementing a proper
law enforcement policy for their community. This makes
In a narrower sense, POLICE denotes the police as an integral part of the criminal justice system,
constitutionally created agency that exercises the power of responsible for apprehending offenders and assisting in
the government concerning the maintenance of their prosecution. According to Charles D. Hale the goals
tranquility, public order, peace, security of persons and and objectives of enforcement of law includes the
property and the protection of public health and morale. following: (1) Crime Prevention, (2) Criminal
Apprehension, (3) Order Maintenance, (4) Public
In a very restricted sense, POLICE refers to that Services and (5) Traffic Regulations and Motor Accident
organization of armed men, which is actually an institution Investigation.
that is capable of exercising legally mandated duties to
enforce the law, maintain public order, and detect and The second goal of police is the [2] PRESERVATION OF
prevent crimes. THE PEACE. This has also been accepted by police as an
Evolution of the word police: important goal. It is known as the peacekeeping and
community service roles. Police have the legal authority
The term police came from the GREEK to arrest individual for disturbing the peace or for
word Politeia (government of a city), which was disorderly conduct. Police are often called to intervenes
used to describe the group of civil officers not only criminal conduct but also in noncriminal
governing the city and not necessarily the armed conduct such as that which occurs at public events, in
men guarding/policing the city. When the social relations and in traffic control to maintain law and
ROMANS conquered the Greeks, they changed the order. They often help the people solve problems that
word slightly to Politia (civil administration) they cannot cope with alone. This is due to the public
which itself derives from the Ancient Greek word impression that the police are also a SOCIAL
polis (city). The FRENCH changed the word to SERVANT and a MEDIATOR to domestic problems.
Police and used it to those authorized people who Hence, the public calls the police for their social services
actually enforce the law. The ENGLISH and the roles, because the police are: (1) constantly available
AMERICANS borrowed the word from the French when needed, (2) dependable when called upon and (3)
and used it to describe a law enforcement capable of providing advice and decision-making
officer. involving interpersonal conflict.
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
3

[3] CRIME PREVENTION is the third goal of the police
pillar which closely related to law enforcement and
peace preservation. If the peace has been kept, crime
has, in effect, been prevented. Crime prevention differs
from peacekeeping and law enforcing in that it attempts with neglected children; rendering emergency medical
to eliminate potentially dangerous or criminal
situations. It is PROACTIVE. If police are highly
visible in a community, crime may be prevented. For provides community education programs regarding
example, a routine patrol might not only discover a
crime in progress, but it might also prevent crimes from
being committed. Crime prevention activities are often
undertaken by police include working with juveniles,
cooperating with probation and parole personnel,
educating the public, instigating operation identification
programs providing visible evidence of police authority.
In addition many community services often provided by
police departments aid in crime prevention. This goal
includes the following activities crime detection, crime
investigation, apprehension of suspects and case
preparation. This police activity is directed toward the
identification and apprehension of alleged criminals and
the accumulation, preservation and presentation of
evidence regarding their crimes. The main objective is to
determine who the criminal is and to develops and
present legally accepted evidence to a court of law so
that a conviction is assured.
The fourth traditional goal of the police is the [4]
PROTECTION OF CIVIL RIGHTS AND CIVIL LIBERTIES
which is perceived by some as the single most important ------------------------------------------------------------------------
goal of policing. This goal is acknowledged in the first
paragraph of the Law Enforcement Code of Ethics: “to D. ANCIENT POLICING SYSTEM
respect the constitutional right of all to liberty, equality
and justice.” The authority, goals and methods of the
police promote individual liberty, public safety and
social justice.
In addition to enforcement of laws, preserving the peace,
prevention of crimes protection of civil rights and
liberties, the police are often called on to provide [5]
ADDITIONAL SERVICES to their community as its fifth (GREECE)
and final goal. This role is acknowledged in the first
sentence of the Law Enforcement Code of Ethics: “As a
law enforcement officer, my fundamental duty is to serve
the community”. It is also acknowledged from the
Philippine National Police motto: “To serve and
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
protect”. The police can provides service to the public
such as giving information; directions and advice;
counseling and referring; licensing and registering
vehicles; intervening in domestic arguments; working
or rescue services; dealing with stray animals; and
controlling traffic and crowds. In addition police
crime, drugs, safety and the like.
➢ THEORIES & CONCEPTS OF POLICE SERVICE
1. Home Rule Theory - The police is considered
servants of the community who depends for the
effectiveness of their functions upon the express
wishes of the people.
2. Continental Theory - Policemen are considered
servants of the higher authority and people have
little or no share of all their duties, nor any direct
connection with them.
3. Old Concept - The old concept of police service
looked upon the police as merely a repressive
machinery.
4. New Concept- regards police as the first line of
defense of CJS, as an organ of crime prevention.
(EGYPT)
1. MEDJAYS - Egyptians (1500 B.C) – Court system
presided by judges appointed by the Pharoah;
Marine patrol & custom house officers protecting
commerce started; first use of dog patrol;
MEDJAYS – civilian police under the command of
a military. Guarding TOMBS.
2. Ancient Greece – EPHORI – law enforcers
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College of Criminal Justice Education
(ROME) and impose punishment. He was assisted by a
Ancient Rome – 12 Tabulae (12 TABLES) – the first written group of constables, the forerunner of the
laws, Emperor Augustus – created the: constabulary. The term Shire-reeve eventually
became Sheriff, the title of the chief of constables
3. PRAETORIAN GUARD – “emperor’s guard”
or police officers in a certain town.
4. URBAN COHORTS – “city patrol”
11. TRAVELING JUDGE – was held responsible in
deciding cases that were taken from Shire-reeves
5. VIGILES – “fire fighters”. The first civilian police
due to some abuses.
force which keep the peace very ruthlessly, hence
the word vigilantes.
12. COURT LEET: to handle local legal matters in
some, but not all, communities, the Normans
(ENGLAND)
established the "Court Leet", which looked after
matters of purely local interest and petty village
6. THANES – It was under King Alfred the Great that
nuisances. The head of the Court Leet was the
a type of internal police force evolved. Alfred
"COMES STABLE", which was a term that means
decreed that the various "thanes" or landowners
"Master of the House". Over a period of time, this
throughout his kingdom were responsible to
word became "Constable" which is still used today
police his own territory, deliver criminals to the
by members of our modern police forces. The
King and to settle civil litigations.
Comes Stable was often appointed by the King but
was also responsible to keep the peace and order
7. FRANKPLEDGE SYSTEM – Policing was carried
in a specific area. This appointee was responsible
out under a system called frankpledge or mutual
to local officials who could petition to have him
pledge, whereby every male over 12 years old join
removed if he did not do his job properly.
nine (9) of his neighbors to form a Tythingmen –
a group of ten (10) men whose duty was to
13. KEEPERS OF THE PEACE - In 1195, King Richard
apprehend any person who offends another and
of England issued a proclamation entitled
deliver that offender for trial. Anyone who failed to
Keepers of the Peace, requiring the appointment
join and perform this obligatory duty was severely
of Knights to keep the King’s peace by standing as
fined. Thus, policing responsibility lies on the
guards on bridges and gates while checking the
hands of the citizens. The head of this group was
people entering and leaving the cities and towns
referred to as a Tythingman
14. JUSTICE OF THE PEACE was a position given to a
8. TUN POLICING – Tun was the forerunner of the
respected citizen, who has the power to arrest,
word “town“. Under this system, ALL MALE
pursue and imprison the offenders.
residents were required to guard the town to
preserve peace and order, protect the life and
15. WATCH AND WARD - Statute of
properties of the people and other factors that
Winchester(1285) was enacted for law and order
disturbs the peace and order.
by king Edward. This law introduced the system of
“WATCH AND WARD”. The primary purpose of
9. HUE AND CRY – In this system, the
the watch and ward was to guard the city gates at
complainant/victim goes to the middle of the
night.
community and shouts to call ALL MALE residents
to assemble. The victim reports his complaint to
16. NIGHT WATCHMEN or BELLMEN - King Charles
the assembly. Consequently, all the male residents
II of England passed a law in 1663 that provided
will go after the criminal and apprehend him.
for the employment of NIGHT WATCHMEN or
BELLMEN to be on duty from sunset to sunrise.
10. SHIRE-REEVE SYSTEM – When King William
Norman became the ruler of England, he divided
17. BOW STREET RUNNERS - In 1748, Henry
his kingdom into 55 military districts known as the
Fielding became the Chief Magistrate at Bow
Shire-Reeves. SHIRE means a district while REEVE
Street in London. He organized a group of men
means the ruler who made laws, pass judgment
known as BOW STREET RUNNERS (thief
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
5

catchers). He later formed the Bow Street Horse
Patrol whose duty was to patrol the main roads
thus secure the travelers from highwaymen or
highway bandits. In 1751, Henry published a
pamphlet entitled An Inquiry into the Causes of
the Late Increase of Robbers, which called for
many sweeping changes in the laws and the
execution of their laws1.
Isabela State University | ECHAGUE
College of Criminal Justice Education
Police employed the first undercover officer.
The great contributions of Sir ROBERT PEEL led
people to regard him the FATHER OF MODERN
POLICING. His most memorable principle was,
"the police are the public, and the public are
the police”
(FRANCE)

NOTA BENE: Bow Street Runners is the First
modern detective force. It is a small group of
volunteers/non-uniformed homeowners often
called "Take Thieves". They hurry to scene of
crime and begin investigation.
18. SCOTLAND YARD - The British statesman SIR
ROBERT PEEL passed with the parliament the
Metropolitan Police Act on September 29, 1829
established the LONDON METROPOLITAN
POLICE, which became the world's first modern
organized police force. It was later called
SCOTLAND YARD. It became model for the
American police system but also had great
influence on the style of policing in almost all
industrial societies. The Metropolitan Police
force was guided by the concept of crime
prevention as a primary police objective. The
force became the model for other police forces
in Great Britain. Informal names are, "the Met"
and "MPS". In statutes it is referred to in the
lower case as the "metropolitan police force" or
the "metropolitan police", without the
appendage "service". The MPS is also referred to
as Scotland Yard after the location of its original
headquarters. The development of the British
police system is especially significant because the
pattern that emerged not only became a model
for the American police system but also had great
influence on the style of policing in almost all
industrial societies.
Police are often referred to as ´BOBBIES´ or
'PEELERS' after Sir Robert (Bobby) Peel. The
primary role of the police in Britain was to keep
the Queen's Peace, which continues into the
present day.
He also introduced the techniques in
detecting crimes such as detectives concealing
themselves, and secretly photographing and
recording conversations. London Metropolitan
19. OFFICERS DE PAIX - In Paris, the position
OFFICERS DE PAIX (origin of “Peace Officer”)
was formed in 1791. This was the origin of the
term Peace Officers
20. SERGENT de VILLE - The French were the first to
establish UNIFORMED POLICE OFFICERS – they
were called SERGENT de VILLE (servant of the
city).
Other contributions of the French in the
development of policing system were:
1. Conceiving street signs.
2. Assigning house numbers.
3. Installing street lighting.
4. Creating emergency and rescue
services.
5. Use of police ambulances.
6. Use of “warrant card”, and ID signifying
authority to arrest.
(AMERICA)
21. RATTLEWATCH - Policing system in America
followed the model developed in England, New
York, Boston and Philadelphia organized their
night watchmen, which was similar to the bellmen
created in London during the reign of King Charles
II. These night watchmen were known as
RATTLEWATCH because they carried rattle while
on duty to inform the public of their watchful
presence.
22. “LEATHERMEN” - in 1638, Night-watch was
initiated in Boston, Massachusetts – they were
called “LEATHERMEN”
23. TEXAS RANGERS – in 1835 - Texas Rangers were
organized

Eduardo, 2008, Notes in Law Enforcement Administration

1

COMPARATIVE MODELS IN POLICING

Reginald C. Sibug, MS CRIM.
6

E. IMPORTANT TERMS
1. COMPARATIVE POLICE SYSTEM
− It is the science and art of investigating and
comparing the police system of nations. It
covers the study of POLICE
ORGANIZATIONS, TRAININGS and
METHODS OF POLICING of various nations.
− Process of outlining the similarities and
differences of one police police system with
the other in order to discover insights in the
field of international policing or coming out
with the best practices in crime prevention
and law enforcement
− Comparative Law Enforcement
Comparative Research Methods
1. “safari” method (a researcher visits another country) or
2. “collaborative” method (the researcher communicates with
a foreign researcher)
------------------------------------------------------------------------
2. COMPARATIVE CRIMINAL JUSTICE
It is subfield of the study of Criminal Justice that
compares justice system worldwide. Such study can
take a descriptive, historical, or political approach .it
studies and differences in structure, goals,
punishment and emphasis on rights as well as the
history and political stature of different systems.
Comparative criminal justice examines the
differences between justice in different kinds of
societies and communities. Those who specialize in
such a field are called comparativists. By studying the
differences in approach, methodology and
effectiveness, they hope to discover better ways of
enforcing laws and ensuring justice for more people.
THREE (3) BASIC FUNCTIONS OF CRIMINAL
JUSTICE SYSTEM
5. COMPARATIVE JUVENILE JUSTICE SYSTEM
• Policing
• Adjudication
• Corrections
------------------------------------------------------------------------
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
3. COMPARATIVE COURT SYSTEM
Court systems of the world are of two types:
(1) Adversarial, where the accused is innocent
until proven guilty. The U.S. adversarial
system is unique in the world. No other
nation, not even the U.K. places as much
emphasis upon determination of factual guilt
in courtroom as the U.S. does.
(2) Inquisitorial, where the accused is guilty
until proven innocent or mitigated, have more
secret procedures. Outside the U.S. most trials
are concerned with legal guilt where
everyone knows the offender did it, and the
purpose is to get the offender to apologize,
own up to their responsibility, argue for
mercy, or suggest an appropriate sentence for
themselves.
Where lesser rights are granted to the
accused and the written law is taken as gospel
and subject to little interpretation.
------------------------------------------------------------------------
4. COMPARATIVE CORRECTIONAL SYSTEM
Correctional systems worldwide can be easily
distinguished by whether they support corporal
punishment (beatings) or not. Some so-called
“civilized’’ countries claim they are better than the
U.S. because they don’t perform death penalty but
actually practice such corporal punishments as
beatings and whippings. Nations that practice
corporal punishment do tend, however, to have less
of a correctional overcrowding problem. Probation
and parole, where they exist cross-culturally, are
applied to the country’s citizens, and not for
foreigners or immigrants.
-----------------------------------------------------------------------
Juvenile justice systems vary widely. Scotland has
the toughest system, regularly sentencing juveniles to
harsh boot camps with a strict military regimen and
force labor. Germany has a juvenile justice system
similar to the U.S., where more emphasis is upon
education as punishment.
7

-----------------------------------------------------------------------
6. INTERNATIONAL CRIMINAL JUSTICE
It involves the study and descriptions of one
country’s law, criminal procedure, or justice process
(Erika Fairchild). Comparative criminal justice
system attempts to build on the knowledge of
criminal justice in one country by investigating and
evaluating, in terms of another country, culture, or
institution.
------------------------------------------------------------------------
7. MODEL SYSTEM
Model system is used to describe the countries
being use as topics of discussion. These countries are
chosen not because they are greater than the others but
because they are the focused of comparison being
studied.
------------------------------------------------------------------------
F. TRANSNATIONAL CRIMES
It is a term that has been used in comparative
international criminal justice study in recent years to
reflect the complexity and enormity of global crime
issues. It is defined by the United Nations (UN) offences
whose inception, proportion and/ or direct or indirect
effects involve in more than one country. Examples are:
• Human trafficking
• Drug trafficking
• Cyber crimes
• Terrorism
• Money laundering
- A transnational organized crime are any of the
following:
1. A crime committed in more than one State.
2. A crime committed in one State but a substantial
part of its preparation, planning, direction or
control takes place in another State.
3. A crime committed in one State but involves a
criminal group that engages in criminal
activities in more than one State.
4. A crime committed in one State but has
substantial affects in another State or States.
UNTOC Convention art 3.2)
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
Transnational Organized Crime
Transnational organized crime involves the
planning and execution of illicit business ventures by
groups or networks of individuals working in more
than one country. These criminal groups use
systematic violence and corruption to achieve their
goals. Crimes commonly include money laundering
Human smuggling; cybercrime; and trafficking of
humans, drugs, weapons, endangered, body parts, or
nuclear materials.
The Major Transnational Organized Crime
Groups
Transnational criminals often operate in well-
organized groups intentionally united to carry out
illegal actions. Groups typically involve certain
hierarchies and are headed by a powerful leader.
These transnational organized crime groups work to
make a profit through illegal activities. Because
groups operate internationally, their activity is a
threat to global security, often weakening
governmental institutions or destroying legitimate
business endeavors.
Well known organized crime groups include:
• SICILIAN MAFIA (Cosa Nostra)
An Italian Mafia organized crime group
originating in the region of Sicily, dating to the
19th century. The Mafia's core activities are
protection racketeering, the arbitration of
disputes between criminals, and the organizing
and oversight of illegal agreements and
transactions.
• AMERICAN MAFIA (La Cosa Nostra)
Known as the Italian or Italian-American
mafia. The most prominent organized crime
group in the world from the 1920s to the 1990s.
They have been involved in violence, arson,
bombing, torture, loan sharking, gambling, drug
trafficking, health insurance fraud, and judicial
corruption.
• YAKUZA
Japanese criminal group. Often involves
in multinational criminal activities, including
8

human trafficking, gambling, prostitution, and
undermining licit businesses.
• RUSSIAN MAFIA (BRATVA)
Around 200 Russian groups that operate
in nearly 60 countries worldwide. They have
been involved in racketeering, fraud, tax evasion
gambling, and drug trafficking, arson, robbery,
and murder.
• FUK CHING
Chinese organized criminal group in the
United States. They have been involved in
smuggling, street violence, and human
trafficking.
• TRIADS
Underground criminal societies based in
Hong Kong. They control secret markets and bus
routes and are often involved in money
laundering and drug trafficking.
• 14K GANG AND “WO SING WO”
Triads, such as “Wo Sing Wo” and 14K
are two of the many triads in Hongkong. They
are involved in various activities ranging from
drug trafficking to corruption.
• UNITED BAMBOO GANG
The largest of Taiwan's three main
 International Definition
Triads.
They are involved in drug trafficking,
prostitution, women and child trafficking.
• JAO PHO
Organize crime group in Thailand. They
are often involved in manufacturing and
trafficking methamphetamine
• “NAM CAM GANG”
One of the most noted organized crime
group in Vietnam and known for drug trafficking
and one of the major transit point of drugs in
Laos, Myanmar, China and Taiwan from
Cambodia.
 Republic Act No. 9208 Definition
• RED WA
Gangsters from Thailand. They are
involved in manufacturing and trafficking
methamphetamine.
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
HUMAN TRAFFICKING
✓ Trafficking in persons is the illegal sale or trading of
persons across borders against their will for financial
gain. It is a form of modern – day slavery. Trafficking
organizations prey on individuals who are poor,
often women who are lured with false promises of
good jobs and better lives and, instead, are forced to
work under brutal conditions.
✓ Trafficking in persons is a crime against humanity. It
further defined for the purposes of commercial
sexual exploitation or force labor: a modern-day
form of slavery. It is the fastest growing criminal
industry in the world, and tied with the illegal arms
industry as the second largest, after the drug trade.
✓ Trafficking in person is the 2nd largest international
crime. It is second place after drug trafficking as
the most profitable illegal industry in the world.
✓ The majority of trafficking victims (teenager) are
between 18 and 24 years of age. An estimated 1.2
million children are trafficked each year. Many
trafficking victims have at least middle-level
education. 600,000 to 800,000 people were
trafficked across international borders every year, of
which 70% were women and 50% children – mostly
for commercial sex trade.
Trafficking in Persons Defined
✓ Trafficking in person is a crime against
humanity. It further defined as act of
recruiting, transporting, transferring,
harboring, or receiving a person through a
use of force, coercion or other means, for the
purpose of exploiting them. Every year,
thousands of men, women and children fall
into the hands of traffickers, in their own
countries and abroad. Every country in the
world is affected by trafficking, whether as a
country of origin, transit or destination for
victims. (United Nation Convention against
Traditional Organized Crime)
✓ Trafficking in person is refers to the recruitment,
transportation, transfer or harboring, or receipt of
persons with or without the victim's consent or
knowledge, within or across national borders by
means of threat or use of force, or other forms of
9

coercion, abduction, fraud, deception, abuse of
power or of position, taking advantage of the
vulnerability of the person, or, the giving or
receiving of payments or benefits to achieve the
consent of a person having control over another
person for the purpose of exploitation which
includes at a minimum, the exploitation or the
prostitution of others or other forms of sexual
exploitation, forced labor or services, slavery,
servitude or the removal or sale of organs.
✓ The recruitment, transportation, transfer,
harboring or receipt of a child for the purpose of
exploitation shall also be considered as
"trafficking in persons" even if it does not involve
any of the means set forth in the preceding
paragraph.
 Republic Act No. 10364 Definition
 Trafficking in Persons – refers to the
recruitment, obtaining, hiring, providing,
offering, transportation, transfer, maintaining,
harboring, or receipt of persons with or without
the victim’s consent or knowledge, within or
across national borders by means of threat, or
use of force, or other forms of coercion,
abduction, fraud, deception, abuse of power or of HUMAN SMUGGLING
position, taking advantage of the vulnerability of
the person, or, the giving or receiving of
payments or benefits to achieve the consent of a
person having control over another person for
the purpose of exploitation which includes at a
minimum, the exploitation or the prostitution of
others or other forms of sexual exploitation,
forced labor or services, slavery, servitude or the
removal or sale of organs.
 "The recruitment, transportation, transfer,
harboring, adoption or receipt of a child for the
purpose of exploitation or when the adoption is
induced by any form of consideration for
exploitative purposes shall also be considered as
‘trafficking in persons’ even if it does not involve
any of the means set forth in the preceding
paragraph.
Elements of Human Trafficking
On the basis of the definition given in the trafficking in
Persons Protocol, it is evident that trafficking in persons
has three constituents’ elements:
• The Act (What is done) - recruitment, obtaining,
hiring, providing, offering, transportation,
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
transfer, maintaining, harboring, or receipt of
persons
• The Means (How it is Done) - Threat or use of
force, coercion, abduction, fraud, deception, abuse
of power or vulnerability, or the giving or
receiving of payments or benefits to achieve the
consent of a person having control over another
person
• The Purpose (Why it is done) – For the purpose of
exploitation, which include exploiting the
prostitution of others, sexual exploitation, forced
labor, slavery, servitude or similar practices and
the removal or sale of organs.
Types of Trafficking in Persons
1. Trafficking of Women for Sexual Exploitation
2. People Smuggling
3. Child Sexual Exploitation
4. Trafficking for Forced Labor/Servitude
5. Trafficking of Organs
✓ Human smuggling is the illicit transfer of people
across borders.
Migrant Smuggling Defined
It is the procurement, in order to obtain, directly or
indirectly, a financial or other material benefit, of the
illegal entry of a person into a state party of which the
person is not a national or permanent resident.”
(Article 3 of the UN Protocol against the
Smuggling of Migrants by Land, Air and Sea).
In contrast to Trafficking in Persons, migrant
smuggling varies in one important way –
victimization. In the case of migrant smuggling the
person involved “voluntarily” submits to being
engaged in criminal activity. Factors such as
economic deprivation, political instability, and
ethnic strife, motivate individuals to cross borders in
search of a better life. Restrictions by governments
on the flow of immigration have therefore created a
lucrative business in the form of migrant smuggling.
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Laws on Human Trafficking in the Philippines
1. Republic Act No. 10364 – the law amending RA
No. 9208. It is otherwise known as the “Expanded
Anti-Trafficking in persons act of 2012.”
2. Republic Act No. 9208 – “Anti-Trafficking in
Persons Act of 2003”. It provides protection and
support to trafficked persons duty of prosecutors
to respect rights of trafficked persons and
provide punishment for traffickers.
3. Republic Act No. 9775 - An Act Defining the
Crime of Child Pornography, Prescribing
Penalties therefor and for other Purposes. It is
otherwise known as the "Anti-Child Pornography
Act of 2009."
4. Republic Act No. 9995 - An Act Defining and
Penalizing the Crime of Photo and Video
Voyeurism, Prescribing Penalties Therefor, and
for Other Purposes. It is otherwise known as the
"Anti-Photo and Video Voyeurism Act of 2009".
5. Republic Act No. 7610- “Special Protection of World Wide Perspective
Children Against Abuse, Exploitation and 1. Middle East - It is the Becka valley of Lebanon is
Discrimination Act”.
6. Republic Act No. 8042- “Migrant Workers and
Overseas Filipino Act”
7. Republic Act No. 6955- “An Act to Declare
Unlawful the Practice of Matching Filipino 2. Spain- It is known as the major transshipment
Women for Marriage to Foreign Nationals on a
Mail-Order Basis and Other Similar Practices
8. Republic Act No. 10906 - An act providing
stronger measures against unlawful practices, 3. South America- Columbia, Peru Uruguay, and
businesses, and schemes of matching and offering
Filipinos to foreign nationals for purposes of
marriage or common law partnership, repealing
for the purpose RA No. 6955, also referred to as
the 'anti-mail order bride law'" penalizes any 4. Morocco- It is known in the world to be the
person who has in any way engaged in business
to exploit Filipinas to offer to foreigners for
marriage
9. Republic Act No. 8239 - “Philippine Passport Act 5. Philippines- It is second to Morroco as to the
of 1996”
DRUG TRAFFICKING
✓ Drug trafficking is also known as illegal drug
trade. It is a global black-market activity
consisting of production distribution packaging
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
and sale of illegal psychoactive substances. It is
simply smuggling across borders, and
distribution within the demand country. This
applies in the local scene where local producer’s
scout demand areas for their illegal drug trade.
✓ Drug trafficking involves SELLING drugs and
drugs paraphernalia, whether it is a local
exchange between a user and a dealer or a
major international operation. Drug trafficking
is a problem that affects every nation in the world
and exists on many levels.
✓ Drug trafficking is the commercial exchange of
drugs and drug paraphernalia. This includes any
equipment used to manufacture illegal drugs or
use them. It is the illegal drug trade or drug
trafficking is a global black market consisting of
the cultivation, manufacture, distribution and sale
of illegal drugs.
considered to be the biggest producer of cannabis
in the middle east. Lebanon is also becoming the
transit country for cocaine for south America to
European illicit drug markets
point for international drug traffickers in Europe
and became ‘’the paradise of drug users in
Europe’’.
panama are the principal sources all cocaine
supply in the world due the robust production of
the coca plants source of the cocaine drug.
number one producer of marijuana. However,
Mexico is still the major producer of cannabis.
production of marijuana. It also became major
transshipment point for the world wide of
distribution of illegal drug particularly shabu and
cocaine from Taiwan and South America. It is also
noted that Philippines today is known as the
“drug paradise of abusers in Asia”.
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College of Criminal Justice Education
6. India- It is the center of the worlds drug map, ✓ Cybercrime is an unlawful act wherein the
leading to rapid addiction among its people. computer is either a tool or a target or both. The
term used to denote the use of computer
7. Indonesia -Northern Sumatra has traditionally technology to engage in unlawful activity.
been the main cannabis growing area in
Indonesia. ✓ Cyber Crime is a term used to broadly describe
criminal activity in which computers or computer
8. Singapore, Malaysia and Thailand- is the most networks are a tool, a target, or a place of criminal
favorable sights of drug distribution from the
activity and include everything from electronic
golden triangle and other part of Asia.
cracking to denial of service attacks. It is also used
9. China - It is the transit route for heroin from to include traditional crimes in which computers
golden triangle to Hong-Kong. It also the country or networks are used to enable the illicit activity
where ephedra plant is cultivated source of drug
ephedrine- the principal chemical for producing Cyber
for drug Shabu. · Refers to a computer or a computer network, the electronic medium in
which online communication takes place.
Hacking or Cracking
10. Hongkong- It is the world transshipment point of
- the unauthorized access into or interference in a computer system,
all forms of heroin. server, or information and communication system; or any access in order
to corrupt, alter, steal, or destroy using a computer or other similar
11. Japan- It became the major consumer of cocaine information and communication devices, without the knowledge and
and shabu from the United State and Europe. consent of the owner (e.g. Denial of Service Attack; Virus Dissemination;
Web Defacement)
Phishing
The Laws on Dangerous Drugs in the Philippines
· a form of identity theft in which scammers send an e-mail message that
1. R.A. 6425 - Dangerous Drugs Act of 1972 appears to come from a legitimate enterprise.
2. R.A. 9165 – Comprehensive Dangerous Drugs Act Pharming
of 2002. Approved on June 7, 2002 - Effective July - a cyberattack intended to redirect a website's traffic to another, fake site.
4, 2002 Pharming attacks compromise at the DNS server level, re-directing you
3. R.A. 9211 - Known as Tobacco Regulation Act of to a hacker's site when you type in a company's Web address.
2003 - Signed into law in June 2003. The
following are the prohibited Acts: Philippine Laws on Cyber Crime
a. Allowing Children to man stalls selling 1. Republic Act no. 10175 - Cyber Crime Law of
tobacco product (s) 2012
b. Selling tobacco products to a minor (under 18
2. Republic Act No. 9775 - An Act Defining the
years of age)
c. Selling of Tobacco products within 100 Crime of Child Pornography, Prescribing
meters from playgrounds, schools and all Penalties Therefor and for other Purposes
youth facilities Cigarette vending machine 3. Republic Act No. 9995 - An Act Defining and
also within the place mentioned Penalizing the Crime of Photo and Video
d. Smoking in Public Places Voyeurism, Prescribing Penalties Therefor, and
for Other Purposes
CYBERCRIMES
✓ Cybercrime is any illegal act committed using a
TERRORISM
computer network (especially the Internet).
✓ The use of violence and threats to intimidate or
✓ Cybercrime is a subset of Computer Crime. coerce especially for political purposes.
‘Cybercrime encompasses any criminal act ✓ Terrorism is the systematic use of terror,
dealing with computers and networks (called especially as a means of coercion. It refers only to
hacking). Additionally, cybercrime also those acts which are:
includes traditional crimes conducted through  Intended to create fear
the Internet.’  Are perpetrated for ideological goal
 Deliberately target non-combatants
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
12

✓ Common definitions of terrorism refer only to
those violent acts which are intended to create fear
(terror), are perpetrated for a religious, political or
ideological goal, and deliberately target or
disregard the safety of non-combatants (civilians).
**Under Section 3 of R.A. 9372, otherwise known as
the Human Security Act of 2007, TERRORISM is the
act of any person who commits an act punishable
under any of the following provisions of the revised
penal code:
✓ Art 122(Piracy and Mutiny)
✓ Art 134 (Rebellion and Insurrection)
✓ Art 134-a (Coup d etat)
✓ Art 248 (Murder)
✓ Art 267 (Kidnapping and serious illegal
detention)
✓ Art 324 (Crimes Involving Destruction)
Or under:
✓ PD 1613 (The Law on Arson)
✓ R.A. 6969 (Toxic Substance Control Act)
✓ R.A. 5207 (Atomic Energy Regulatory Act)
✓ R.A. 6235 (Anti-Hijacking Law)
✓ PD 532 (Anti-Piracy and Highway Robbery)
✓ PD1866 (Illegal Possession of Fire Arms)
Penalty: Life imprisonment without the benefit of
thereby sowing and creating a condition of
parole.
widespread and extraordinary fear and panic
among populace, in order to coerce the
government to give in to an unlawful demand MONEY LAUNDERING
shall be guilty of the crime of terrorism and shall ✓ Money laundering is the process of creating the
suffer the penalty of 40 years of imprisonment
without the benefit of parole
**Under Section 4 of R.A. 11479, otherwise known as
the “The Anti-Terrorism Act of 2020”, TERRORISM is
committed by any person, who within or outside the
Philippines, regardless of the stage of execution:
a) Engages in acts intended to cause death or
serious bodily injury to any person or endangers
a person's life;
b) Engages in acts intended to cause extensive
damage or destruction to a government or public
facility, public place, or private property;
c) Engages in acts intended to cause extensive
interference with, damage, or destruction to
critical infrastructure;
d) Develops, manufactures, possesses, acquires,
transports, supplies or uses weapons, explosives
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
Isabela State University | ECHAGUE
College of Criminal Justice Education
or of biological, nuclear, radiological or chemical
weapons; and
e) Release of dangerous substances or causing fire,
floods or explosions
when the purpose is to intimidate the general public,
create an atmosphere of fear or to spread a message
of fear, to provoke or influence by intimidation the
government or any international organization,
seriously destabilize or destroy the fundamental
political, economic, or social structures in the
country, or create a public emergency or seriously
undermine public safety.
The definition further states that "advocacy, protest,
dissent, stoppage of work, industrial or mass action,
and other similar exercises of civil and political rights"
shall not be considered as terrorist acts ONLY if
they "are not intended to cause death or serious
physical harm to a person, to endanger a person's life,
or to create a serious risk to public safety."
appearance that large amounts of money obtained
from illegal means.
Three (3) Basic Steps to change Illicit Funds to
Legitimate Funds
1. Placement– This is the first step of the money-
laundering process and the ultimate aim of this
phase is to remove the cash from the location of
acquisition so as to avoid detection from the
authorities. It involves a changing the bulk cash
derived from criminal activities into a more
portable and less suspicious form, then getting
those proceeds into the mainstream financial
system.
Example: Dividing large amount of money into less
smaller terms that are deposited directly into
different bank account.
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 Isabela State University | ECHAGUE
College of Criminal Justice Education
2. Layering – Layering involves moving funds through salaries, rent,– COLLEGE
ISABELA STATE UNIVERSITY andOF CRIMINAL
leasJUSTICE
onEDUCATION
non- existing
around the financial system, often in a complex assets. ORGANIZED CRIME INVESTIGATION
by: Reginald C. Sibug, MSCrim.
serious of transactions to create confusion and A typical Money Laundering Scheme
complicate the paper trail.
- It involves the movement of these funds, 1
PREDICATE CRIME
often mixed with funds of legitimate origins,
through the world’s financial systems in
numerous accounts in an attempt to hide 2
the funds back into the mainstream
economy, where they can be invested and PLACEMENT
spent freely.
- To conceal the illegal origin of the placed
funds and thereby make them more useful,
Dirty money integrates into the
the funds must be moved, dispersed and financial system
disguised i.e. layering. Collection of Dirty money
LAYERING
- At this stage, money launderers use many 3
different techniques to layer the funds in Transfer on the
bank account of
order to disguise their origins. company X.

Example: (1) having professionals act as

intermediaries and transacting through Loan to
corporations and trusts, (2) transferring funds to Company
Y
numerous accounts in one or more financial Payment by Y of
false invoice to
Wire Transfer
institutions. (3) Movements of money into company X

different accounts and different countries. Purchase of luxury asset,

financial investment and
commercial and industrial Offshore Banking
3. Integration – The ultimate goal of money investment

laundering process is integration. Once the funds 4 INTEGRATION

are in the financial system and insulated through
the layering stage, the integration stage is used
to create the appearance of legality through
additional transactions.
- It is the process of reintroducing these
layered funds back into the mainstream
economy, where they can be invested and
spent freely.
- Laundered funds are made available for
activities such as investment in legitimate
or illegitimate businesses, or spent to
promote the criminal's lifestyle. At this
stage, the illegal money has achieved the
appearance of legitimacy. It should be
noted that not all money laundering
transactions go through this three-stage
process. Transactions designed to launder
funds can also be affected in one or two
stages, depending on the money laundering
technique being used.

Example: Purchase or resale of real estate,

investment in securities etc. or funnel such money
into various dummy firms and get repaid
COMPARATIVE MODELS IN POLICING
Reginald C. Sibug, MS CRIM.
14
 Isabela State University | ECHAGUE
College of Criminal Justice Education

ACTIVITIES
Learning Task #1

1. Base on the definition of Comparative Police

System, as future law enforcers, what do you think
are the importance of studying it?

2. Give hypothetical examples of the following

theories and concepts in policing:
a. Home Rule Theory
b. Continental Theory
c. Old Concept
d. New Concept

ACADEMIC REQUIREMENT #1b:

“TRANSNATIONAL CRIMES”
❖ Watch the following videos and make a reaction
paper about the content of the said videos. Write
first the name/title of each videos before your
answers(“reaction/comments”).
a. https://www.youtube.com/watch?v=Ozty0bdayvg
b. https://www.youtube.com/watch?v=3jPoS1TZ6fU&pbjreload=101
c. https://www.youtube.com/watch?v=1ObJPaSZxCs
d. https://www.youtube.com/watch?v=8KseFc_v-k4

COMPARATIVE MODELS IN POLICING

Reginald C. Sibug, MS CRIM.
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