Case Digest (G.R. No. 2307)
Facts:
The United States v. Chu Chang, G.R. No. 2307. April 09, 1906, the Supreme Court En Banc, Carson, J., writing for the Court.The United States (plaintiff and appellee) prosecuted Chu Chang (defendant and appellant) for the crime of corruption of minors under Article 444 of the Penal Code. At trial the court found facts that led to a conviction: the accused, as master, kept a minor in his house who engaged in prostitution with various Chinese men, and the accused promoted or facilitated that prostitution. The trial court concluded that the relation of master and servant existed between the accused and the girl and that the accused took advantage of his position to effect the prostitution, with the consequence that the accused was convicted.
On appeal to the Supreme Court, counsel for the appellant argued that, although the trial court’s facts might support conviction as an accomplice to rape, they did not establish the offense of corruption of minors because (1) it had not been shown that the accused acted with abuse of authority or abuse of confidential relation, and (2) the minor ultimately consented to the carnal relations with other men, which the appellant argued negated the offense charged.
The Supreme Court reviewed the trial record, found the trial court’s factual findings fully sustained by the evidence, invoked an 1883 decision of the Supreme Court of Spain to treat the master–servant relation as a relation of conf...(Pro-only)
Issues:
- Did the evidence sustain the conviction of Chu Chang for corruption of minors under Article 444 of the Penal Code?
- Does the minor’s subsequent consent to carnal relations, or the absence of shown abuse of authority, defeat a conviction under Article 444 when the accused...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
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Doctrine:
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