Case Digest (G.R. No. 9279)
Facts:
- The case involves the United States as the plaintiff and Saturnino Capillo and Petrona Paduga as the defendants.
- The events occurred on August 12, 1913, in Manila, Philippine Islands.
- Capillo and Paduga were accused of exposing Capillo's legitimate child, a one-month-old infant, to lose his civil status.
- The prosecution alleged that Capillo, in conspiracy with Paduga, took the child without the consent of the mother, Vicenta Umanbang.
- They intended to deliver the child to Chua Pue Tee, with plans to never reclaim it.
- They sought a loan of P150 from Chua Pue Tee for expenses related to Umanbang's illness and death, ultimately receiving P106.
- The prosecution argued that this act could render the child an unknown child or the child of Chua Pue Tee.
- On August 21, 1913, the defendants pleaded not guilty.
- On September 1, 1913, their counsel filed a motion similar to a demurrer, claiming the information lacked sufficient facts to constitute a crime under Article 468 of the Penal Code.
- The Court of First Instance of Manila dismissed the case, agreeing that the information did not state sufficient facts to constitute a crime.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the lower court's decision, ruling that the information did not state sufficient facts to constitute the crime charged.
- The court held that the defendants' actions did not fall under Article 468 of the Penal Code, which pertains...(Unlock)
Ratio:
- The court's reasoning focused on the interpretation of "expusiere" (to expose) as used in Article 468 of the Penal Code.
- The term was understood in the context of abandonment, supported by historical and linguistic analysis.
- The statute was intended to penalize acts of abandonment leading to th...continue reading
Case Digest (G.R. No. 9279)
Facts:
The case involves the United States as the plaintiff and Saturnino Capillo and Petrona Paduga as the defendants. The events took place on August 12, 1913, in Manila, Philippine Islands. The prosecution accused Capillo and Paduga of exposing Capillo's legitimate child, a one-month-old infant, to lose his civil status. The information alleged that Capillo, in conspiracy with Paduga, took the child without the consent of the child's mother, Vicenta Umanbang, and agreed to deliver the child to a certain Chua Pue Tee, with the intent of never reclaiming it. They also sought a loan of P150 from Chua Pue Tee to cover expenses related to Umanbang's illness and death, ultimately receiving P106. The prosecution argued that this act exposed the child to lose its civil status as the legitimate son of Capillo and Umanbang, potentially rendering him an unknown child or the child of Chua Pue Tee.
On August 21, 1913, the defendants pleaded not guilty. Subsequently, on September 1, 1913, their counsel filed a motion akin to a demurrer, asserting that the information did not present sufficient facts to constitute a crime under Article 468 of the Penal Code. The defendants contended that the statute did not apply to their actions, as the law was primarily relevant to situations involving the concealment or exposure of a child by a person entrusted with it...