Com. v. Rosario Maldonado, L., Com. v. Rosario Maldonado, L. No. 1442 MDA 2016

On February 17, 2014, Appellant Luis Epifanio Rosario Maldonado sexually assaulted a 16‑year‑old female; charges included IDSI, aggravated indecent assault, indecent assault, corruption of minors, rape, sexual assault, and unlawful restraint.
Victim testified Appellant blocked exits, threatened her with a knife, forced oral sex and intercourse multiple times, and injured her; SAFE nurse documented recent injuries and a labial laceration and described Victim as a "good historian."
Police testimony corroborated Victim’s identification of the knife and the house layout; Appellant gave inconsistent statements and admitted to performing oral sex; vaginal swabs contained saliva DNA consistent with Appellant.
Jury convicted Appellant of IDSI, aggravated indecent assault, indecent assault, and corruption of minors; court sentenced him to concurrent terms (longest 7–14 years for IDSI).
Appellant moved for a new trial arguing the verdict was against the weight of the evidence based on Victim’s alleged lack of credibility; post‑sentence motion denied, appeal reinstated nunc pro tunc.
Appellate counsel filed an Anders/Santiago brief seeking leave to withdraw, arguing the weight claim was frivolous; this Court conducted an independent review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the convictions are against the weight of the evidence such that a new trial is required	Commonwealth: evidence (victim testimony, nurse’s findings, police corroboration, DNA) sufficiently proved elements and credibility determinations are for the jury	Maldonado: victim was not credible; verdict "shocks the conscience" and weight favored acquittal	Court: trial court did not abuse discretion; weight claim fails — jury could credit victim and corroborating evidence; appeal frivolous
Whether appellate counsel may withdraw under Anders/Santiago	Commonwealth (implicitly): counsel complied with procedural requirements for withdrawal	Maldonado: may pursue pro se or new counsel if he chooses	Court: counsel substantially complied with Anders/Santiago; granted leave to withdraw after independent review

Anders v. California, 386 U.S. 738 (procedural protections when counsel seeks to withdraw)
Commonwealth v. Santiago, 978 A.2d 349 (Pa. 2009) (clarifies Anders requirements for court‑appointed appellate counsel)
Commonwealth v. Champney, 832 A.2d 403 (Pa. 2003) (standard of review for weight‑of‑the‑evidence claims)
Commonwealth v. Palm, 903 A.2d 1244 (Pa. Super. Ct.) (appellate court performs independent review after Anders compliance)
Commonwealth v. Wrecks, 934 A.2d 1287 (Pa. Super. Ct.) (substantial compliance with Anders/Santiago is sufficient)
Commonwealth v. McClendon, 434 A.2d 1185 (Pa.) (discussed in context of Anders briefing requirements)