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...

Facts:

1. Parties Involved:

   • Plaintiff and Appellant: The United States.
   • Defendants and Appellees: Saturnino Capillo and Petrona Paduga.

2. Charges:

   • The defendants were accused of the crime of exposing a legitimate child to lose his civil status under Article 468 of the Penal Code.

3. Allegations:

   • On or about August 12, 1913, in Manila, Saturnino Capillo and Petrona Paduga conspired to expose Capillo’s one-month-old legitimate child to lose his civil status.
   • Capillo, with the intent to cause the child to lose his civil status, took the child without the mother’s permission or court authority and agreed with Chua Pue Tee to deliver the child to him, promising never to reclaim it.
   • In exchange, Capillo and Paduga received P150 from Chua Pue Tee, with P50 going to Capillo and P56 to Paduga.
   • The child’s living under Chua Pue Tee’s care allegedly exposed him to the risk of losing his civil status as the legitimate son of Capillo and his wife, Vicenta Umanbang.

4. Procedural History:

   • The defendants pleaded not guilty on August 21, 1913.
   • On September 1, 1913, the defendants filed a motion to dismiss, arguing that the facts alleged in the information did not constitute a crime under Article 468 of the Penal Code.
   • The Court of First Instance of Manila treated the motion as a demurrer and dismissed the case, holding that the information did not state facts sufficient to constitute the crime charged.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Interpretation of "Expusiere":

   • The court interpreted the word "expusiere" (to expose) in Article 468 of the Penal Code to mean "to abandon" a child in a manner that exposes it to the risk of losing its civil status. This interpretation is based on the historical context of the term in Spain, where it referred to the practice of abandoning newborns at churches or public places.
   • The court rejected the prosecution’s argument that "expusiere" includes any act that subjects a child to the risk of losing its civil status, as this interpretation is not supported by the dictionary definition or the grammatical construction of the statute.

2. Elements of the Crime:

   • The crime under Article 468 requires:
     (a) The concealment or abandonment of a legitimate child.
     (b) The intent to cause the child to lose its civil status.
   • The court found that the information did not allege an act of abandonment in the sense required by the statute. Instead, it described a transaction where the child was delivered to another person with a promise not to reclaim it, which does not constitute the crime defined in Article 468.

3. Limitations of Article 468:

   • The court clarified that Article 468 does not penalize the sale or transfer of a child by its parent, even if such conduct is morally reprehensible. If the accused’s actions constitute a different crime, they should be charged under the appropriate statute.

4. Grammatical Construction:

   • The court emphasized that the verbs "ocultare" (to conceal) and "expusiere" (to expose) in Article 468 must be interpreted consistently. Since "ocultare" cannot be construed to include the risk of losing civil status, "expusiere" should not be given such an extended meaning.

Conclusion:

The Supreme Court affirmed the dismissal of the case, holding that the acts alleged in the information did not constitute the crime of exposing a legitimate child to lose his civil status under Article 468 of the Penal Code. The court clarified that the statute is limited to acts of abandonment that expose a child to the risk of losing its civil status and does not cover the transfer of a child to another person for consideration.