UNITED STATES V. WILLIAM FOWLER ET AL.

(GR No. 496. December 31, 1902)

FACTS: On August 12, 1901, respondents William Fowler and another unnamed
defendant were accused of the theft of 16 bottles of champagne, valued at $20, belonging
to one Julian Lindsay. The alleged act was committed whilst aboard the transport
“Lawton” which was travelling on the high seas during the act.
The respondents’ counsel then presented an objection, stating that the Court of First
Instance did not have jurisdiction over the case. The reasons being: (1) the crime was
committed on the high seas, (2) the crime was not committed in the city of Manila, and
(3) the crime was not committed within the 3-mile limit to which the court’s jurisdiction
extends. Counsel argues that the case be dismissed.
The judge then ordered that the case be dismissed and the defendants be discharged as
the Court of First Instance of Manila did not have jurisdiction over the case. Prosecuting
attorney then files an appeal at the Supreme Court.
ISSUE: Whether or not the Court of First Instance of Manila has jurisdiction over the
criminal theft case committed on August 12, 1901 aboard a vessel sailing on the high
seas.
HELD: NO. Act No. 136 of the Organic Law as well as Act No. 186 issued by the Civil
Commission do not confer jurisdiction upon said court to take cognizance of crimes
committed whilst aboard a vessel on the high seas.
Furthermore, Act No. 400, in Article 1, paragraph 8, states “…of all crimes and offenses
committed on the high seas or beyond the jurisdiction of any country, or within any of the
navigable waters of the Philippine Archipelago, on board a ship or water craft of any kind
registered or licensed in the Philippine Islands in accordance with the laws thereof."

Since the transport Lawton is a vessel not registered or licensed in the Philippine Islands, the
Court of First Instance of Manila does not have jurisdiction to take cognizance of the
aforementioned crime.