GR L 496; (December, 1902) (Digest)
G.R. No. L-496, December 31, 1902
THE UNITED STATES, complainant-appellant, vs. WILLIAM FOWLER, ET AL., defendants-appellees.
FACTS:
The defendants, William Fowler and others, were accused of the theft of sixteen bottles of champagne valued at $20 on August 12, 1901. The crime was committed on board the transport Lawton while it was navigating the high seas. The stolen property formed part of the vessel’s cargo and belonged to Julian Lindsay. The prosecution alleged that the defendants took the bottles lucri causa and with intent to appropriate them, without violence or the owner’s consent. Upon arraignment, the defendants demurred, arguing that the Court of First Instance of Manila lacked jurisdiction because the theft occurred on the high seas, outside the territorial waters (3-mile limit) and the geographical jurisdiction of the court. The prosecution opposed, contending that under orders of the Military Governor and Acts Nos. 76 and 186 of the United States Civil Commission, the court had been vested with admiralty jurisdiction over crimes committed on vessels flying the U.S. flag. The trial judge sustained the demurrer, holding that the court lacked jurisdiction, and ordered the defendants’ discharge. The prosecution appealed.
ISSUE:
Whether the Court of First Instance of Manila has jurisdiction to try a criminal case for theft committed on board a U.S. transport vessel navigating the high seas.
RULING:
No. The Supreme Court affirmed the trial court’s order dismissing the case for lack of jurisdiction. The Court held that while Acts Nos. 136 and 186 of the Civil Commission addressed civil admiralty or maritime cases, they did not expressly confer jurisdiction over criminal cases committed on the high seas. The Court clarified that Act No. 400, which amended Act No. 136, specifically defined the criminal jurisdiction of Courts of First Instance under Article 56(8) to cover crimes committed “on the high seas or beyond the jurisdiction of any country… on board a ship or water craft of any kind registered or licensed in the Philippine Islands.” Since the transport Lawton was not a vessel registered or licensed under Philippine laws, the local courts lacked jurisdiction to try the offense. The order of dismissal was affirmed, with costs de oficio.