TERRITORIALITY
G.R. NO. L-18924: OCTOBER 19, 1922
THE PEOPLE OF THE PHILIPPINE ISLANDS, Plaintiff-Appellant, v. WONG CHENG
(alias WONG CHUN), Defendant-Appellee.
Ponente: ROMUALDEZ, J.:
FACTS:
The appellant, in representation of the Attorney General, filed an appeal that urges the
revocation of a demurrer sustained by the Court of First Instance of Manila presented
by the defendant. The defendant, accused of having illegally smoked opium aboard the
merchant vessel Changsa of English nationality while the said vessel was anchored in
Manila Bay, two and a half miles from the shores of the city. In the said demurrer, the
defendant contended the lack of jurisdiction of the lower court of the said crime, which
resulted to the dismissal of the case.
ISSUE/S:
Whether or not the Philippine courts have jurisdiction over the crime committed aboard
merchant vessels anchored in our jurisdictional waters.
RULING:
Yes. The crime in the case at bar was committed in our internal waters thus the
Philippine courts have a right of jurisdiction over the said offense. The Court said that
having the opium smoked within our territorial waters even though aboard a foreign
merchant ship is a breach of the public order because it causes such drugs to produce
pernicious effects within our territory. Therefore, the demurrer is revoked and the Court
ordered further proceedings.