THE UNITED STATES Vs H.N. BULL - G.R. No.: L-5270 | Criminal Cases | Case Digest

THE UNITED STATES Vs H.N. BULL
G.R. No.: L-5270 - January 15, 1910

Facts:

The defendant, H.N. Bull, captain and master of the Norwegian steamer known as the Standard, was engaged in the transportation of cattle and carabaos from Chinese and Japanese ports to and into the city of Manila, Philippine Islands. He was accused of willfully, unlawfully and wrongly transport and bringing into the port and city of Manila, aboard said vessel, 677 cattle and carabaos, without providing suitable means for securing the animals. While in transit, the noses of some of said animals were cruelly torn, and many of said animals were tossed about upon the decks and hold of said vessel, and were cruelly wounded, bruised and killed.



Issues:

1.Whether or Not the court has jurisdiction to hear and determine the case

2.Whether or Not the defendant knowingly and willfully failed to provide suitable means for securing said animals

Ruling:

1. Yes. No court of the Philippine Islands had jurisdiction over an offenses or crime committed on the high seas or within the territorial waters of any other country, but when it came within 3 miles of a line drawn from the headlines which embrace the entrance to Manila Bay, it was within territorial waters, and a new set of principles became applicable. From the line which determines these waters the Standard must have traveled at least 25 miles before it came to anchor. During that part of the voyage the violation of the statue continued, and as far as the jurisdiction of the court is concerned, it is immaterial that the same conditions may have existed while the vessel was on the high seas. The offense, assuming that it originated at the port of departure in Formosa, was a continuing one, and every element necessary to constitute it existed during the voyage across the territorial waters. The completed forbidden act was done within American waters, and the court therefore had jurisdiction over the subject-matter of the offense and the person of the offender.

2. Yes. The allegation of the complaint that the act was committed willfully includes the allegation that it was committed knowingly. As said in Woodhouse vs. Rio Grande R.R., "the word 'willfully' carries the idea, when used in connection with an act forbidden by law, that the act must be done knowingly or intentionally; that, with knowledge, the will consented to, designed, and directed the act." So in Wong vs. City of Astoria, it was said: "The first one is that the complaint did not show, in the words of the ordinance, that the appellant 'knowingly' did the act complained of. This point, I think, was fully answered by the respondent's counsel, that the words 'willfully' and 'knowingly' conveyed the same meaning. To 'willfully' do an act implies that it was done by design, done for a certain purpose; and I think that it would necessarily follow that it was 'knowingly' done."

The evidence shows not only that the defendant's acts were knowingly done, but his defense rests upon the assertion that "according to his experience, the system of carrying cattle loose upon the decks and in the hold is preferable and more secure to the life and comfort of the animals."


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