G.R. No. 496 - People vs. Fowler

The defendants, William Fowler et al., were accused of theft of sixteen bottles of champagne worth $20.
The theft allegedly occurred on August 12, 1901, while on board the transport ship Lawton navigating the high seas.
The champagne was part of the cargo owned by Julian Lindsay.
The defendants were alleged to have taken the bottles lucri causa, with intent to appropriate, without violence, intimidation, or owner’s consent, contrary to law.

Defendants appeared before the Court of First Instance.
The prosecuting attorney represented the Government.
Defendants’ counsel filed a demurrer claiming that the Court of First Instance had no jurisdiction since the crime was committed on the high seas beyond the court’s territorial jurisdiction (outside Manila, the Bay of Manila, and the 3-mile limit).
The prosecuting attorney opposed, arguing:

The court has original jurisdiction over criminal cases with penalties exceeding six months imprisonment or fines over $100.
Military Governor and Civil Commission orders vested admiralty jurisdiction for crimes on ships flying the United States flag in the Courts of First Instance in Manila (citing the August 14, 1898 order and Acts Nos. 76 and 186).
The President of the United States authorized establishment of judicial system with maritime jurisdiction in the Philippines, analogous to US Supreme Court decisions and precedents from territories during the Mexican and Civil Wars.

The Court of First Instance ruled, by order dated September 14, 1901, that it lacked jurisdiction over the offense committed on the high seas, sustained the demurrer, and discharged defendants with costs against the Government.
The prosecuting attorney appealed the order.
The case reached the Supreme Court of the Philippines for resolution.

Whether the Court of First Instance has jurisdiction to try criminal offenses committed on the high seas aboard a vessel flying the United States flag but not registered or licensed in the Philippine Islands.
Whether Acts Nos. 76, 136, 186, and 400, and presidential or military orders confer criminal admiralty jurisdiction to Philippine courts over crimes committed on such vessels on the high seas.