US v.

Bull

The United States vs. H.N. Bull

GR L-5270
Jan 15, 1910

Facts:

On the 2nd of December 1908, a steamship vessel engaged in the transport of animals named Standard
commanded by H.N. Bull docked in the port of Manila, Philippines. It was found that said vessel from
Ampieng, Formosa carried 677 heads of cattle without providing appropriate shelter and proper suitable
means for securing the animals which resulted for most of the animals to get hurt and others to have
died while in transit.

This cruelty to animals is said to be contrary to Acts No. 55 and No. 275 of the Philippine Constitution.

It is however contended that cases cannot be filed because neither was it said that the court sitting
where the animals were disembarked would take jurisdiction, nor did it say about ships not licensed
under Philippine laws, like the ship involved.

Issue:

Whether or not the court had jurisdiction over an offense committed on board a foreign ship while
inside the territorial waters of the Philippines.

Held:

No court of the Philippines has jurisdiction over any crimes committed in a foreign ship on the high seas,
but the moment it entered into territorial waters, it automatically would be subject to the jurisdiction of
the country. The offense, assuming that it originated in Formosa, which the Philippines would have no
jurisdiction, continued until it reached Philippine territory which is already under jurisdiction of the
Philippines.

Every state has complete control and jurisdiction over its territorial waters. The Supreme Court of the
United States has recently said that merchant vessels of one country visiting the ports of another for the
purpose of trade would subject themselves to the laws which govern the ports they visit, so long as they
remain.

Defendant is thereby found guilty, and sentenced to pay a fine with subsidiary imprisonment in case of
insolvency, and to pay the costs.
Donato v. Luna

Leonilo C. Donato vs. HON. ARTEMON D. LUNA, PRESIDING JUDGE, COURT OF FIRST INSTANCE OF
MANIIA, BRANCH XXXII HON. JOSE FLAMINIANO, CITY FISCAL OF MANILA; PAZ B. ABAYNA
GR No. L-53642
April 15, 1988

Facts:

On January 23, 1979, a criminal case of bigamy was filed against petitioner Donato.

On September 28, 1979 private respondent filed a civil action for the declaration of nullity of her
marriage with petitioner contracted on September 26, 1978 on a certain ground that petitioner did not
know that respondent has already married a certain Rosalinda R. Manluping on June 30, 1978. Petitioner
Donato answered that his second marriage is supposedly null and void because it was contracted
without marriage license, and that force, intimidation and undue influence were employed by
respondent to obtain his consent to the marriage.

Prior to the date of the trial for the criminal case, petitioner filed a motion to suspend the hearing of the
criminal case contending that the civil case filed against him would raise a prejudicial question which
must first be decided before the criminal case can proceed.

Issue:

Whether or not the decisions that can be taken from the criminal case of bigamy filed would result to a
prejudicial question that may affect the decision to be made in the hearing for the civil actions filed and
thus should it be suspended while hearing for the civil case is made.

Held:

A prejudicial question has been defined to be one which arises in a case, the resolution of which
question is a logical antecedent of the issue involved in said case, and the cognizance of which
pertains to another tribunal. It must appear not only that said case involves facts intimately related to
those upon which the criminal prosecution would be based but also that in the resolution of the issue
or issues raised in the civil case, the guilt or innocence of the accused would necessarily be
determined.

The requisites of a prejudicial question do not obtain in the case at bar. It must be noted that the
issue touching upon the nullity of the second marriage is not determinative of petitioner Donato's
guilt or innocence in the crime of bigamy.
Pursuant to the doctrine discussed in Landicho vs. Relova, petitioner Donato cannot apply the rule
on prejudicial questions since a case for annulment of marriage can only be considered as a
prejudicial question to the bigamy case against the accused only if it is proved that the petitioner's
consent to such marriage was obtained by means of duress, violence and intimidation in order to
establish that his act in the subsequent marriage was an involuntary one and as such the same
cannot be the basis for conviction. The preceding elements do not exist in the case at bar.

In the case at bar, the motion to suspend the criminal case does not take any merit and is dismissed.