本文旨在比较分析两地刑法中的不作为犯的异同,通过“小悦悦事件”引出中国内地与澳门在刑法中与实践中对不作为犯规定的不同,对两地现有的规定结合刑法典进行分析,着重比较两地不作为犯的义务来源之异同,通过对两地不作为犯问题的探讨,从而借鉴与完善中国内地的规定。 The purpose of this article is to compare and analyze the similarities and differences between the non-inmates in the criminal law between the two places. By “Small Yue Yue Incident”, this article draws the difference between the Mainland and Macao in criminal law and in practice that they stipulate the non- It stipulates that the criminal code should be combined with the analysis to focus on comparing the similarities and differences in the sources of obligations of the two places as offenders and to learn from and improve the provisions in mainland China through discussions on the issue of non-commissioned offenses in both places.