An eleven-year-old Bukidnon girl was carried away from northern Mindanao to Bohol by a Filipino school-teacher who had been discharged from the insular service. Her parents gave every indication of bitter grief and begged to have their daughter restored to them. This was finally accomplished, to their great joy, as a result of my efforts. The kidnapper was ultimately brought into court, but before the case came up for trial the parents had been subjected to such "influence" that when called to the witness-stand they swore that the kidnapper had taken their daughter with their full knowledge and consent. In order to be reasonably effective, laws in these islands must be so framed as to make it possible to protect people too ignorant, or too timid, to protect themselves. Returning now to the Supreme Court decision, the court also held that:-- "... the defendant appears to have engaged in the business of buying in Nueva Vizcaya children to sell in the lowlands of Isabela." But it further held that:-- "Not even the abhorrent species of traffic apparently carried on by the accused justifies a sentence not authorized by law." More important still, the court held that:-- "The judge below quotes the Bill of Rights of the Philippines contained in the Act of Congress of July 1, 1902, declaring that 'neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist in said Islands.' This constitutional provision is self-acting whenever the nature of a case permits and any law or contract providing for the servitude of a person against his will is forbidden and is void. For two obvious reasons, however, it fails to reach the facts before us:-- "First. The employment or custody of a minor with the consent or sufferance of the parents or guardian, although against the child's own will, cannot be considered involuntary servitude. "Second. We are dealing not with a civil remedy but with a criminal charge, in relation to which the Bill of Rights defines no crime and provides no punishment. Its effects cannot be carried into the realm of criminal law without an act of the legislature," and also that:-- "To sum up this case, there is no proof of slavery or even of involuntary servitude, inasmuch as it has not been clearly shown that the child has been disposed of against the will of her grandmother or has been taken altogether out of her control. If the facts in this respect be interpreted otherwise, there is no law applicable here, either of the United States or of the Archipelago, punishing slavery as a crime." In view of the facts above cited the necessity for legislation seemed obvious.