Us vs. Fowler, Us vs. Bull Case Digests

US vs. FOWLER G.R. No. L-49631 J. Torres FACTS: This is an appeal to the Supreme Court by the appellant, the United States, to review the decision made by the Court of First Instance (CFI) of Manila. The two defendants and appellees, Fowler et al, have been accused of the theft of sixteen (16) bottles of champagne of the value of $20 on 12 August 1901 while on board the transport Lawton. Lawton was then navigating the high seas. The said champagne bottles are part of the cargo and are owned by Julian Lindsay. The said champagne bottles were taken lucri causa, without violence or intimidation and without the consent of the owner. ISSUE: Whether or not the CFI of Manila has jurisdiction over the criminal case, theft, committed on board while navigating on high seas. HELD: The accused claim that the CFI of Manila has no jurisdiction over the case as the crime was committed on high seas and not in the city of Manila or within the territory comprising the Bay of Manila or upon the 3-mile limit which the jurisdiction extends. The prosecution contends that the Military General and Civil Commission admiralty has jurisdiction over all vessels flying the flag of the United States and the same was vested in the CFI of Manila. CFI held that it has no jurisdiction over the case. Hence, the appeal to the Supreme Court. Art. 136, by which the courts of justice of the Philippine Islands were organized, do not expressly confer jurisdiction or confer authority upon the court in Manila. The provisions of the law are clear only on civil and maritime cases but not on criminal cases committed on board. Art. No. 400, states that the Philippines has jurisdiction only with the crimes committed in a ship registered in the Philippines or those within the territorial jurisdiction of the Philippines. Lawton is neither a ship registered in the Philippines nor within the territorial jurisdiction of the Philippines. SC affirmed the decision of the lower court. LATIN MAXIM: lucri causa- the thing to which it applies is done for the sake of gain. At case it in hand, this is used to emphasize the crime.

OTHER POINTS: *high seas- in maritime law, all parts of the mass of saltwater surrounding the globe that are not part of the territorial sea or internal waters of a state. ** territorial waters is not necessarily defined as it is define in our law today since this is case before the present constitution. ***for this case, focus on Art. 2. Paragraph 2 of the Revised Penal Code to apply it in the present time. US vs. Bull FACTS:    

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December 2, 1908 Steamship Standard- Vessel for transportation of animals Ampieng, Formosa – Manila route H.N. Bull – master, unlawfully, willfully, wrongfully transport 677 cattles and carabaos without suitable means for securing while in transit (stalls, tying, securing, tied by means of rings passed through their noses), deck of the vessel had no beddings. Wounded, bruised, killed animals

HELD: The Court has jurisdiction. Bull PI has no jurisdiction Insufficent? Standard is a Norwegian ship, not registered in PI. Crime committed constitute offense within US territory, high seas Court PI has jurisdiction Sufficient-Adequate Suitable means for the protection of animals (Act no 275) 3 miles within PI, territorial sovereignty, continuing offense. Merchant vessel- purpose of trade in PI, inconvenience and danger to society Disembarkation is unnecessary. PI is not a state of US. Phil Congress has liberty in IRR.

Animals were not disembarked in the Manila Port Art. 55 (adopted as basis for judgment) is unconstitutional as amended by Art 1,3 of US Consti Suitability of handling must be left to the judgment of the master CFI and SC – Convicted.

Unsecured – 15 cattles with broken legs and 3 dead