Com. v. Morales, M., Com. v. Morales, M. No. 833 MDA 2016

Victim Xavier Garriga was found shot and later died from a through-and-through chest wound after police responded to a 3:20 a.m. 911/phone-ping report on June 21, 2014.
Crime scene yielded three spent shell casings and a spent .40 caliber bullet; video, time-distance, and trajectory evidence were presented at trial.
Mathew Stefan Morales was tried by jury over four days and convicted of first-degree murder; the court sentenced him to life without parole on February 16, 2016.
Morales filed post-sentence motions (including a weight-of-the-evidence claim); procedural complications produced an untimely appeal which was later reinstated nunc pro tunc and pursued in the Superior Court.
The Commonwealth relied largely on circumstantial evidence and witness testimony (including eyewitness and forensic witnesses) to prove premeditation and that Morales fired the fatal shot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence for first-degree murder	Commonwealth: evidence and inferences support conviction	Morales: insufficiency, particularly lack of premeditation	Court: Issue waived on appeal; even if reviewed, evidence sufficed and conviction stands
Weight of the evidence	Commonwealth: jury properly weighed witness credibility and corroborating physical evidence	Morales: key witnesses (Fuentes, Jones, Sears) were not credible; verdict shocks conscience	Court: Trial court did not abuse discretion; verdict not so contrary to evidence as to warrant new trial

Commonwealth v. Diamond, 83 A.3d 119 (Pa. 2013) (standard for sufficiency review)
Commonwealth v. Colon-Plaza, 136 A.3d 521 (Pa. Super. 2016) (sufficiency need not exclude every possibility of innocence)
Commonwealth v. Robertson-Dewar, 829 A.2d 1207 (Pa. Super. 2003) (evidentiary sufficiency principles)
Commonwealth v. Tejada, 107 A.3d 788 (Pa. Super. 2015) (fact-finder may credit or discredit testimony)
Commonwealth v. Mucci, 143 A.3d 399 (Pa. Super. 2016) (criminal convictions may rest on circumstantial evidence)
Commonwealth v. Rogal, 120 A.3d 994 (Pa. Super. 2015) (appellate court may not reweigh evidence)
Commonwealth v. Woodard, 129 A.3d 480 (Pa. 2015) (issue preservation and briefing requirements)
Wirth v. Commonwealth, 95 A.3d 822 (Pa. 2013) (failure to develop appellate argument waives claim)
Commonwealth v. Gonzalez, 109 A.3d 711 (Pa. Super. 2015) (weight-of-evidence principles)
Commonwealth v. Clay, 64 A.3d 1049 (Pa. 2013) (standards for weight-of-the-evidence review)
Commonwealth v. Widmer, 744 A.2d 745 (Pa. 2000) (trial court discretion on new trial for weight claims)
Commonwealth v. Brown, 648 A.2d 1177 (Pa. 1994) (new trial standard for verdict contrary to evidence)
Commonwealth v. Diggs, 949 A.2d 873 (Pa. 2008) (trial court denial of weight claim is least assailable)
Commonwealth v. Farquharson, 354 A.2d 545 (Pa. 1976) (deference to trial court’s opportunity to observe witnesses)