Case Summary (G.R. No. 5270)
Petitioner and Respondent
Petitioner/Appellant: H. N. Bull (vessel master)
Respondent/Appellee: United States Government
Key Dates
Alleged offense: on or about December 2, 1908
Decision date: January 15, 1910
Applicable Law
– Act No. 55 (January 1, 1901), as amended by Act No. 275 (October 23, 1901): duties and penalties for livestock transport between foreign ports and Philippine ports, including provision of adequate forage, water, and securing facilities to prevent cruelty.
– Section 3 of Act No. 55: penalties ($100–$500) and venue (Courts of First Instance or provost courts at place of disembarkation).
– Organic Act of 1902; Spooner Amendment (Army Appropriation Act, March 2, 1901): framework for Philippine civil government and local legislative power.
– U.S. Constitution, Article IV, Section 3, Paragraph 3 (Congress’s power over U.S. territory).
– Act No. 400: jurisdiction over offenses on the high seas or within Philippine waters on board any vessel registered or licensed in the Philippines.
Issue 1 – Jurisdiction and Sufficiency of the Information
Bull contended the complaint failed to allege disembarkation in Manila or Philippine registry of the vessel. The Court held that under Act No. 55 venue lies in the court of the port into which animals are brought, not necessarily after disembarkation, and no registry allegation is required to establish jurisdiction.
Issue 2 – Territorial Jurisdiction over a Continuing Offense
Though the Standard was a Norwegian ship, the cruelty continued within three miles of Manila Bay. The Court applied U.S. and international law principles: once in territorial waters, a continuing offense aboard a merchant vessel falls within local jurisdiction. The violation persisted during the vessel’s approach, so the Philippine court had authority over both subject matter and person.
Issue 3 – Nationality of the Vessel and Exterritoriality
Warships enjoy limited immunity by comity; merchant vessels do not. Citing U.S. Supreme Court precedent (The Schooner Exchange) and treaty interpretations, the Court confirmed that merchant ships in port for trade submit to local criminal laws unless a treaty provision expressly waives jurisdiction. No treaty prohibited this prosecution.
Issue 4 – Mental Element (“Willfully” vs. “Knowingly”)
The appellant argued the information omitted “knowingly.” The Court determined that alleging the act was done “willfully” inherently includes knowledge. Jurisprudence confirms “willfully” implies intentional and knowing conduct, satisfying due process in criminal pleading.
Issue 5 – Constitutionality of Acts No. 55 and No. 275
Because the decision predates the 1987 Constitution, the Court applied the constitutional scheme governing U.S. territories: Congress’s plenary power under Article IV to establish rules for U.S. territory, delegated to the Philippine Commission and later the Philippine Legislature under the Organic Act and
...continue readingCase Syllabus (G.R. No. 5270)
Facts
- H. N. Bull was master of the steamship Standard, a Norwegian vessel, engaged in transporting cattle and carabaos from Ampieng, Formosa, to Manila, Philippine Islands.
- On December 2, 1908, Bull brought aboard and transported 677 head of cattle and carabaos into Manila Bay without providing suitable means—stalls, ties, bedding—to secure the animals and avoid cruelty.
- As a result, many animals were bruised, some had torn nostrils from rings, several were wounded, and others died or suffered broken legs.
- The Court of First Instance of Manila convicted Bull under Section 1 of Act No. 55, as amended by Section 1 of Act No. 275, and imposed a fine of ₱250 with subsidiary imprisonment for insolvency, plus costs.
Procedural History
- Bull appealed to the Supreme Court of the Philippine Islands, assigning errors as follows:
- The complaint failed to state facts sufficient to confer jurisdiction.
- The trial court lacked jurisdiction under the evidence.
- Act No. 55, as amended, violated the U.S. Constitution as applied.
- The evidence was insufficient to support conviction.
- The Supreme Court heard oral and written arguments, including extensive discussion of jurisdictional and constitutional issues.
Issues
- Does the complaint confer subject-matter and personal jurisdiction on the local court?
- Can Philippine courts exercise jurisdiction over offenses committed aboard a foreign merchant vessel within territorial waters?
- Are merchant ships exempt by public law or treaties from local criminal jurisdiction?
- Does the complaint sufficiently allege the requisite mens rea (“willfully” and “knowingly”)?
- Is Act No. 55, as amended by Act No. 275, constitutional under the organic law of the Philippine Government and the U.S. Constitution?
Statutory Offense and Jurisdictional Grant
- Act No. 55 (effective January 1, 1901) requires masters of vessels carrying animals into Philippine ports to:
- Carry sufficient forage and water.
- Provide forage and water at least once every 24 hours.
- Act No. 275 (October 23, 1901) amends Section 1 to require:
- Suitable means (stalls, ties, facilities) to avoid cruelty and unnecessary suffering.
- Proper loading and unloading facilities; prohibits swinging cattle by horns.
- Section 3 of Act No. 55 imposes penalties of $100–$500 per offense and confers jurisdiction on any Court of First Instance or provost court in the province or port of disembarkation.