G.R. No. 74630 & 75576. September 30, 1991. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAIDA TOMIO alias SATO TOSHIO and NAKAJIMA TAGAHIRO alias YAMADA TAKAO, accused-appellants. IN THE MATTER OF PETITION FOR HABEAS CORPUS OF TADAHIRO NAKAJIMA and TOMIO MAEDA, petitioners.
FACTS

Japanese tourist Tatsumi Nagao was approached by appellants and an associate in Manila. They later planted marijuana on him, leading to his apprehension by alleged policemen. Appellants then acted as interpreters, informing Nagao he faced a long prison term unless he paid a $100,000 bribe, which they claimed to have advanced. They subsequently escorted and confined Nagao across multiple hotels and a condominium, controlling his movements and coercing him to contact his family in Japan to secure ransom money for his release. Appellants were arrested while receiving partial payment at a bank. An Information for Kidnapping for Ransom was filed after an ex-parte preliminary investigation under General Order No. 39. Appellants were arraigned and tried over three days, convicted, and sentenced to death, prompting automatic review. A separate petition for habeas corpus was consolidated, challenging the trial court’s jurisdiction.

ISSUE

The primary issue is whether the trial court acquired jurisdiction over the persons of the appellants and the subject matter, and whether the conviction for kidnapping for ransom was proper.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The trial court validly acquired jurisdiction. The filing of the Information by the fiscal conferred jurisdiction over the subject matter. Appellants voluntarily submitted to the court’s authority by entering a plea and participating in the trial without raising jurisdictional objections, thereby waiving any defect from the alleged lack of a preliminary investigation. On the merits, the elements of kidnapping for ransom were established. Appellants, through deception and intimidation, deprived Nagao of his liberty. Their acts of escorting, confining, and isolating him while demanding money from his family constituted detention for the purpose of extorting ransom. The defense of being mere interpreters and helpers was rejected, as their coordinated actions demonstrated conspiracy. The penalty was reduced because the death penalty statute (RA 7659) was not yet in effect at the time of the crime’s commission in May 1986. The petition for habeas corpus was dismissed as moot.