Subject: Generality and Territoriality

US v. Philip K. Sweet
G.R. no. 448
September 20, 1901

Facts:
Philip K. Sweet is an employee of the United States military authorities in the
Philippines. He allegedly assaulted a prisoner of war in their custody. Appellant argued that such
offense is not punishable under the Penal code, and the same is of military character which
should exempt him from being tried in a civil court.

Issue:
Does the appellant Sweet be subject to the jurisdiction of the civil tribunals?

Ruling:
Yes. The civil courts have the right to acquire jurisdiction over appellant. The Court
stated that the offense committed by a military person has incurred a criminal responsibility
which arose from an infraction of the general penal laws. Moreover, the general principle applies
that the jurisdiction of the civil tribunals is unaffected by the military or other special character
of the person brought before them for trial. The Court further adds that there is no conflict
between the two jurisdictions in the present case nor any claim of jurisdiction on the part of the
military tribunal