Com. v. Mateo, E., 1784 MDA 2016

Background

On Oct. 15, 2013, occupants of a gold Buick were shot; Jordan Breeland died and Davon Brown was injured. Police later located two suspects, Elvin Mateo and Durell Cotton, who fled on foot and were apprehended after allegedly discarding handguns.
A .357 Rossi recovered near Mateo during the foot pursuit contained DNA highly likely to be Mateo’s; ballistics linked a bullet fragment from the Buick to that .357. Gunshot residue was found on Mateo’s clothing and hands.
Witnesses placed a maroon/red SUV fleeing the shooting scene; owner Belinda Akers identified Cotton (co-defendant) as the borrower of that SUV. Raymond Bruno‑Carrasquillo testified Mateo admitted “lurking” for Parkway gang members, renting/using a burgundy SUV that night, and shooting into the victims’ car.
At trial the Commonwealth relied largely on circumstantial evidence and eyewitness/corroborative testimony; Mateo did not testify. The jury convicted Mateo (and Cotton) of conspiracy to commit murder, first‑degree murder, attempted first‑degree murder, and aggravated assault.
Mateo filed post‑sentence motions challenging weight and sufficiency of evidence and admissibility of a statement that he sold drugs; the trial court denied relief and the Superior Court affirmed.

Issues

Issue	Commonwealth's Argument	Mateo's Argument	Held
Whether the verdict was against the weight of the evidence	Verdict supported by abundant circumstantial and corroborative evidence (Bruno‑Carrasquillo’s admissions, ballistics, DNA, GSR, vehicle evidence).	Verdict shocks conscience because self‑defense/initial aggressor not disproved and murder weapon not produced.	Denied — trial court found no valid self‑defense theory, evidence sufficiently probative, verdict did not shock the conscience.
Whether evidence was legally sufficient to support convictions	Evidence (direct and circumstantial) permitted jury to find every element beyond a reasonable doubt.	Insufficient because self‑defense not disproved and lack of murder weapon undermines proof.	Denied — court found sufficiency satisfied; Mateo also waived specificity for sufficiency claim in his Rule 1925(b) statement.
Whether trial court erred admitting Detective Fetrow’s testimony that Mateo said he sold drugs	Testimony admissible to corroborate Bruno‑Carrasquillo’s testimony and relevant to placing defendants together and motive/activities that night.	Prejudicial character evidence; probative value outweighed by prejudice.	Denied — court exercised discretion under Rule 404(b) to admit the statement as corroborative; probative value exceeded prejudicial effect.
Whether self‑defense was properly presented to jury	No evidence supported a valid claim of self‑defense; instruction arguably unnecessary but harmless.	Self‑defense was a viable theory and Commonwealth failed to disprove it.	Denied — court found no evidence to support self‑defense; even if instruction given, Commonwealth had no burden to disprove it because it was not properly raised.

Key Cases Cited

Champney v. Commonwealth, 832 A.2d 403 (Pa. 2003) (standard for appellate review of weight claims and factfinder’s role in assessing credibility)
Jones v. Commonwealth, 874 A.2d 108 (Pa. Super. 2005) (sufficiency review: view evidence in light most favorable to verdict winner; circumstantial evidence may suffice)
Ballard v. Commonwealth, 80 A.3d 380 (Pa. 2013) (trial court discretion on admissibility of evidence; reversal only for abuse causing prejudice)
Widmer v. Commonwealth, 744 A.2d 745 (Pa. 2000) (weight‑of‑the‑evidence standard; trial court not a thirteenth juror)
Torres v. Commonwealth, 766 A.2d 342 (Pa. 2001) (defendant need only produce some evidence to place self‑defense at issue)
Ramtahal v. Commonwealth, 33 A.3d 602 (Pa. 2011) (circumstantial evidence can sustain convictions)
Gillespie v. Commonwealth, 434 A.2d 781 (Pa. Super. 1980) (Commonwealth bears burden to disprove self‑defense if defense properly at issue)