The father has a right to the services and earnings of his minor children while under his care and protection, unless such right has been voluntarily relinquished by him. This is based upon the idea of compensation to the parent for the duty of maintenance.8

A child can recover for domestic services rendered to a parent only where there has been an express promise on the part of the parent to pay for such services. The burden of proof is on the child to prove such promise. The marriage of a child, after reaching the age of consent, will work a complete emancipation of the child from the control of the father.

A mother is entitled to the earnings of her minor children after the death of her husband. The mother would also be entitled to the earnings of her children when both she and the children had been deserted by the husband and father and the children were living under her care.