Com. v. Santiago, M.

CourtSuperior Court of Pennsylvania
DecidedSeptember 19, 2025
Docket1496 EDA 2024
StatusUnpublished

This text of Com. v. Santiago, M. (Com. v. Santiago, M.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Com. v. Santiago, M., (Pa. Ct. App. 2025).

Opinion

J-S25037-25

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

COMMONWEALTH OF PENNSYLVANIA : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : MANUEL LUIS SANTIAGO : : Appellant : No. 1496 EDA 2024

Appeal from the Judgment of Sentence Entered November 14, 2023 In the Court of Common Pleas of Northampton County Criminal Division at No(s): CP-48-CR-0001467-2021

BEFORE: PANELLA, P.J.E., DUBOW, J., and BENDER, P.J.E.

MEMORANDUM BY BENDER, P.J.E.: FILED SEPTEMBER 19, 2025

Appellant, Manuel Luis Santiago, appeals from the aggregate judgment

of sentence of 10 to 20 years’ incarceration, imposed after a jury convicted

him of various sexual offenses committed against two minor, female victims.

Appellant was also deemed to be a sexually violent predator (SVP). On appeal,

Appellant challenges the court’s admission of certain evidence, the

discretionary aspects of his sentence, and the sufficiency of the evidence to

support his designation as an SVP. After careful review, we affirm.

Briefly, Appellant’s convictions stemmed from evidence that he sexually

assaulted his two nieces, S.C. and M.S.1 S.C. alleged that Appellant sexually

assaulted her from 2015 to 2016, beginning when she was 11 years old. M.S.

____________________________________________

1 Appellant was also charged with various offenses based on allegations of sexual assault by his daughter, A.S. However, the jury was deadlocked and unable to reach a verdict as to any charges pertaining to A.S. J-S25037-25

alleged that Appellant sexually assaulted her from 2017 to 2018, beginning

when she was 12 years old. Following a jury trial in 2022, Appellant was

convicted of two counts each of indecent assault (18 Pa.C.S. § 3126(a)(7)),

unlawful contact with a minor – sexual offenses (18 Pa.C.S. § 6318(a)(1)),

and corruption of a minor (18 Pa.C.S. § 6301(a)(1)(ii)). 2

On August 21, 2023, the court conducted an SVP hearing. On October

12, 2023, it issued an order deeming Appellant to be an SVP. On November

14, 2023, the court sentenced him to the aggregate term of incarceration set

forth supra. On November 24, 2023, Appellant timely filed a post-sentence

motion. After that motion was denied by operation of law on May 17, 2024,

Appellant filed a timely notice of appeal on May 21, 2024. 3 Appellant and the ____________________________________________

2 Appellant was found not guilty of two counts of aggravated indecent assault

of a child (18 Pa.C.S. § 3125(b)), and one count of attempted rape (18 Pa.C.S. § 901(a) (criminal attempt); 18 Pa.C.S. § 3121(a)(1) (rape)).

3 Pursuant to Pa.R.Crim.P. 720(B)(3)(a), the trial court had 120 days to decide

the November 24, 2023 post-sentence motion, which here would have made the deadline Monday, March 25, 2024. On March 1, 2024, however, the court entered an order granting a 30-day extension for a decision on the motion. See Pa.R.Crim.P. 720(B)(3)(b) (“Upon motion of the defendant within the 120-day disposition period, for good cause shown, the judge may grant one 30-day extension for decision on the motion. If the judge fails to decide the motion within the 30-day extension period, the motion shall be deemed denied by operation of law.”). Because the trial court did not decide the post- sentence motion within 150 days, the clerk of courts should have entered an order on April 22, 2024, stating that the post-sentence motion was deemed denied. See Pa.R.Crim.P. 720(B)(3)(c) (requiring the clerk of courts to enter an order on behalf of the court when a post-sentence motion is deemed denied by operation of law). However, an order denying the post-sentence motion was not entered until May 17, 2024, 175 days after the filing of the November 24, 2023 post-sentence motion. This Court has previously held that a (Footnote Continued Next Page)

-2- J-S25037-25

court complied with Pa.R.A.P. 1925. Herein, Appellant states three issues for

our review:

1. Did the trial court err and abuse its discretion when it admitted the news article related to Appellant’s charges dated May 4, 2021? Relatedly, did the trial court err when it instructed the jury on Appellant’s alleged flight on May 5, 2021[,] as evidence of consciousness of guilt?

2. Did the trial court err and abuse its discretion when it imposed an above[-]aggravated[-]range sentence that was unreasonable and excessive because it failed to adequately consider mitigating factors, considered factors already contemplated within the sentencing guidelines, and considered impermissible factors?

3. Did the trial court err and abuse its discretion when it found that Appellant met the criteria to be classified as a sexually violent predator?

Appellant’s Brief at 9.

In his first issue, Appellant argues that the “[t]he trial court erred and

abused its discretion when it allowed Detective Stephen O’Donnell to testify

regarding a newspaper article about the charges against [Appellant] published

breakdown occurs when the clerk of courts fails to enter an order deeming a post-sentence motion denied by operation of law and notifying the defendant of the same. See Commonwealth v. Perry, 820 A.2d 734, 735 (Pa. Super. 2003). When a trial court denies a post-sentence motion after the 120-day period and the appellant then files an appeal within 30 days of the date of that decision, this Court has found that the notice of appeal is timely. See id.; see also Commonwealth v. Braykovich, 664 A.2d 133 (Pa. Super. 1995) (holding that the appellant’s notice of appeal was timely, as it was filed within 30 days of an untimely order denying the appellant’s post-sentence motion). Here, even though the clerk of courts failed to enter an order on April 22, 2024, denying the post-sentence motion by operation of law, Appellant’s May 21, 2024 notice of appeal was filed within thirty (30) days of the May 17, 2024 order denying his post-sentence motion. Accordingly, we deem the instant appeal as timely filed.

-3- J-S25037-25

the night before the police attempted to execute an arrest warrant for …

Appellant.” Id. at 24. The trial court provided further context for Appellant’s

claim, as follows:

Detective O’Donnell of the North Catasauqua Police Department testified that on May 5, 2021, he and three other officers attempted to execute a felony arrest warrant for [Appellant] at 1209 Third Street, Catasauqua, where [Appellant] resided with his parents. N.T.[ Trial,] 10/20/22[,] at 35, 39. [Appellant’s] mother answered the door and advised officers that [Appellant] had been in his bedroom. Id. at 44-45. The bedroom door was locked, so [Appellant’s] mother called his cellphone, which could be heard ringing inside the room. Id. at 45-47. When officers proceeded to the side of the residence, they observed the window of the ground-floor bedroom open and the screen pushed out, with no occupants inside. Id. at 50-51, 58. Detective O’Donnell then testified that the evening prior to his attempt to execute the arrest warrant, a newspaper article was published detailing the allegations against [Appellant]. Id. at 59, 63-64. The article was admitted into evidence at Commonwealth Exhibit 16. Id. at 64- 66. The defense objected that the testimony regarding the article was irrelevant, and that it was speculative as to whether [Appellant] was aware of the article. Id. at 59-63. The [c]ourt concluded that the topic could be appropriately addressed on cross-examination and through closing arguments. Id. at 62-63.

Trial Court Opinion (TCO), 8/26/24, at 7-8.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Moody
843 A.2d 402 (Superior Court of Pennsylvania, 2004)
Commonwealth v. Moury
992 A.2d 162 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Paul
925 A.2d 825 (Superior Court of Pennsylvania, 2007)
Commonwealth v. Mouzon
828 A.2d 1126 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Braykovich
664 A.2d 133 (Superior Court of Pennsylvania, 1995)
Commonwealth v. Young
989 A.2d 920 (Superior Court of Pennsylvania, 2010)
Commonwealth v. Sierra
752 A.2d 910 (Superior Court of Pennsylvania, 2000)
Commonwealth v. Perry
820 A.2d 734 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Mann
820 A.2d 788 (Superior Court of Pennsylvania, 2003)
Commonwealth v. MacIas
968 A.2d 773 (Superior Court of Pennsylvania, 2009)
Commonwealth v. Bullock
170 A.3d 1109 (Superior Court of Pennsylvania, 2017)
Commonwealth v. Hunzer
868 A.2d 498 (Superior Court of Pennsylvania, 2005)
Commonwealth v. Shugars
895 A.2d 1270 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Evans
901 A.2d 528 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Dixon
907 A.2d 533 (Superior Court of Pennsylvania, 2006)
Commonwealth v. Griffin
65 A.3d 932 (Superior Court of Pennsylvania, 2013)
In re Zimmerman Stove Heater Corp.
293 F. 1023 (Second Circuit, 1923)

Cite This Page — Counsel Stack

Bluebook (online)
Com. v. Santiago, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/com-v-santiago-m-pasuperct-2025.