It could only be construed that way if you assume every document had to specifically spell out the civil procedures to be followed, not only the religious ones. And if you also assume children need to be spelled out distinctly from adults in every case. Both are silly assumptions.
This document did not protect bishops, priests, or anyone else from punishment if they covered up civil crimes. More to the point, it certainly did not instruct the bishops to undertake such a coverup. The fact that these topics were not covered in this single document does not imply anything.
One would also have to keep in mind that different countries have VERY DIFFERENT civil procedures and concepts of law. In the 1961-62 period, for instance, priests had been imprisoned in totalitarian countries for trumped up charges of various kinds. In the current media cycle people have gotten used to the idea of automatically viewing the priests as guilty and of the Church as having covered up actual terrible crimes. This was not always the case in past history. In the Communist countries dominated by the Soviet Union, innocent priests were often jailed. Whether a homosexual subculture as vast as that which has existed since the 1970s was present in the Church of the past is highly debatable. Solicitation of sex by priests would probably have been directed at women with a frequency greater than that of the homosexual sodomy/rape cases of recent headlines. That false charges of sexual misconduct have been directed at priests would have been something to be concerned about as well. This doesn't excuse cover-ups, of course.
I don't expect it to spell out civil procedures, but when a SERIOUS CRIME has been committed by a clergyman and there is NO MENTION of civil authorities, it makes it seem that the church is above any laws but their own. Furthermore, the victim is NOT bound by the seal of confession and could easily be intimidated by the church proceedings, as many undoubtedly were, to defer from reporting the crime to the civil authorities.
This document did not protect bishops, priests, or anyone else from punishment if they covered up civil crimes. More to the point, it certainly did not instruct the bishops to undertake such a coverup. The fact that these topics were not covered in this single document does not imply anything.
Yes, it did to the extent that the church took the law into its own hands and meted out a punishment or not, as it deemed appropriate, bypassing civil law.
To my knowledge, as of this point in time, there has been NO mention that serious criminals should be turned over to civil authorities, where the knowledge of the crime was gained outside the boundaries of confession. If you know of such a document or instructions, I would like to know about it.
I don't like the idea that any crime committed by clergy is exempt from scrutiny in the light of just secular laws. It doesn't work that way for penitents who have committed serious crimes who *may* be instructed by their confessor to turn themselves over to civil authorities.
Also the issue of threatening the victim with excommunication if he fails to come forward after learning of the requirements to do so (most victims would be ignorant of this canon) within 30 or whatever number of days seems stacked against the victim and in favor of the clergy which comes across to me as unjust. If a person goes to a clergyman (apart from confession) and reports an abuse, the clergyman is not threatened with excommunication if he fails to report it to anyone.
I can't determine what the INTENTION of the excommunication threat is meant to accomplish on the poor victim.