US vs BULL

G.R. No. L-5270, January 15, 1910

FACTS
• On December 2, 1908, a steamship vessel engaged
in the transport of animals named Stanford
commanded by H.N. Bull docked in the port of
Manila, Philippines. It was found that said vessel
from Ampieng, Formosa carried 674 heads of cattle
without providing appropriate shelter and proper
suitable means for securing the animals which
resulted for most of the animals to get hurt and
others to have died while in transit.
FACTS
• This cruelty to animals is said to be contrary to Acts
No. 55 and No. 275 of the Philippine Constitution.
It is however contended that cases cannot be filed
because neither was it said that the court sitting
where the animals were disembarked would take
jurisdiction, nor did it say about ships not licensed
under Philippine laws, like the ships involved.
ISSUE
• Whether or not the court had jurisdiction over an
offense committed on board a foreign ship while
inside the territorial waters of the Philippines.
HELD
• Yes. The court had jurisdiction over an offense
committed on board a foreign ship while inside the
territorial waters of the Philippines.
RATIO
• When the vessel comes within 3 miles from the
headlines which embrace the entrance of Manila Bay,
the vessel is within territorial waters and thus, the laws
of the Philippines shall apply. A crime committed on
board a Norwegian merchant vessel sailing to the
Philippines is within the jurisdiction of the courts of the
Philippines if the illegal conditions existed during the
time the ship was within the territorial waters -
regardless of the fact that the same conditions existed
when the ship settled from the foreign port and while it
was on the high seas.