Miquiabas vs.

Philippine-Ryukyus Command

Petitioner: Jesus Miquiabas

Respondent: Commanding General, Philippine-Ryukyus Command, United States Army

Facts:
-Petitioner is a Filipino citizen and a civilian employee of the United States Army in the
Philippines
-Petitioner has been charged with disposing in the Port of Manila Area of things belonging to
the United States Army
-Petitioner was arrested, tried by a General Court Martial, found guilty and sentenced to 15
years imprisonment.
-Petitioner filed a writ of habeas corpus arguing that the General Court-Martial has him
under custody and trial for an offense in which said court has no jurisdiction.

Issue:
WON the General Court-Martial has jurisdiction to try petitioner for the offense allegedly
committed by him.

Held:
No. The case is not covered by the Bases Agreement entered into by the Philippines and the
United States because petitioner is not a member of the United States Armed Forces and he alleged
offense was not committed within any US base.

Doctrine:
Bases Agreement
March 14, 1947

“The Philippines consents that the United States have the right to exercise jurisdiction over the
following offenses:

(a) Any offense committed by any person within any base, except where the offender and the
offended party are both Philippine citizens (not members of the armed forces of the United
States on active duty) or the offense is against the security of the Philippines;
(b) Any offense committed outside the bases by any member of the armed forces of the United
States in which the offended party is also a member of the armed forces of the United
States; and
(c) Any offense committed outside the bases by any member of the armed forces of the
United States against the security of the United States.”