Commonwealth v. Naranjo
53 A.3d 66
| Pa. Super. Ct. | 2012Background
- Appellant Alex M. Naranjo was convicted of possession of an instrument of crime (PIC) and sentenced to 2.5 to 5 years, after a jury acquitted him of murder charges.
- The incident occurred at about 5:00 a.m. on January 24, 2008, culminating in the death of Reo Dennis from a stab wound in Philadelphia.
- Appellant admitted stabbing Dennis but claimed self-defense; he brought three weapons to the scene and wore a scarf over his face.
- There was competing testimony about whether the weapons could have caused the fatal injury; the scene weapons included a scissors, a metal ruler, and a multi-purpose tool with a knife extended.
- The jury was instructed that self-defense could preclude PIC; it nonetheless convicted Appellant of PIC, while not convicting him of homicide.
- Appellant challenged both sufficiency of the PIC evidence and the sentence as outside the guidelines, asserting the court relied exclusively on Dennis’s death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of PIC evidence after self-defense acquittal | Naranjo contends no criminal intent shown for PIC given self-defense acquittal on homicide. | Commonwealth argues additional evidence of intent to employ weapons criminally supports PIC. | Sufficiency upheld; evidence showed intent to use weapons to fight, not merely possess. |
| Discretionary sentencing outside guidelines | Sentence relied solely on Dennis’s death; excessive under sentencing guidelines. | Court weighed multiple factors and pre-sentence report; not unreasonable. | Sentence affirmed; not unreasonable given record and factors. |
Key Cases Cited
- Commonwealth v. Mobley, 14 A.3d 887 (Pa. Super. 2011) (sufficiency; standard for reviewing circumstantial evidence)
- Commonwealth v. Gonzalez, 527 A.2d 106 (Pa. 1987) (self-defense acquittal and PIC conviction conflict)
- In re A.C., 763 A.2d 889 (Pa. Super. 2000) (possession of knife for self-defense cannot establish PIC)
- Commonwealth v. Moore, 49 A.3d 896 (Pa. Super. 2012) (PIC reversed when homicide acquittal based on self-defense lacked other criminal-intent evidence)
- Commonwealth v. Corley, 31 A.3d 293 (Pa. Super. 2011) (sentencing factors and reviewability under 42 Pa.C.S. § 9781)
- Commonwealth v. Macias, 968 A.2d 773 (Pa. Super. 2009) (relevant to weighing factors in discretionary sentencing)
- Commonwealth v. Garcia-Rivera, 988 A.2d 777 (Pa. Super. 2009) (substantial question for discretionary review; sentencing guidelines)
- Commonwealth v. Briggs, 12 A.3d 291 (Pa. 2011) (malice related to various degrees of homicide)