Com. v. Salinas, R., 307 A.3d 790

Ramon Salinas was convicted of summary Harassment (18 Pa.C.S. § 2709(a)(3)) in Pike County following an incident with his neighbor, Joseph DiPietro.
The incident involved Salinas and his son passing DiPietro twice in a car, during which they shouted threats and vulgar remarks.
Both Salinas and his son were originally convicted by a magistrate judge, then appealed for a trial de novo at the Court of Common Pleas.
At trial, the court credited DiPietro’s testimony over Salinas's, finding sufficient evidence for a course of conduct constituting Harassment.
Salinas was sentenced to a $300 fine and subsequently appealed, challenging both the sufficiency and weight of the evidence.

Issue	Salinas's Argument	Commonwealth's Argument	Held
Sufficiency of evidence: Did Salinas engage in a “course of conduct” under § 2709(a)(3)?	Only made one statement, which was not a pattern or course of conduct.	Turned car around, passed DiPietro twice, and made threats, demonstrating continuity.	Evidence sufficient; two acts in close succession can be a course of conduct.
Weight of the evidence: Was the conviction against the weight of evidence?	Intoxalock records show Salinas was not near the scene, supporting his alibi.	Trial court found DiPietro’s account credible and rejected Salinas's timeline.	No abuse of discretion; trial court’s credibility finding stands.

Commonwealth v. Rushing, 99 A.3d 416 (Pa. 2014) (setting standard for sufficiency review)
Commonwealth v. May, 887 A.2d 750 (Pa. 2005) (evidence, including circumstantial, must meet all elements beyond reasonable doubt)
Commonwealth v. Miller, 172 A.3d 632 (Pa. Super. 2017) (credibility determinations are for the factfinder)
Commonwealth v. Tedesco, 550 A.2d 796 (Pa. Super. 1988) (course of conduct requires more than an isolated act, showing a pattern)
Commonwealth v. Lutes, 793 A.2d 949 (Pa. Super. 2002) (course of conduct can be established by multiple acts over a short span)