Supreme Court of Puerto Rico

El Pueblo v. Negrón Ramírez

April 23, 20242024 TSPR 41

Summary

The court reversed the intermediate appellate court and reinstated the defendant’s convictions, holding that the jury could reasonably find digital vaginal penetration beyond a reasonable doubt from the victim’s testimony, gestures, and demonstrations. The court held that the appellate court abused its discretion by substituting a transcript-based assessment for the jury’s evaluation of live testimony without any recognized exception to appellate deference. It also rejected the claim that reinstatement violated double-jeopardy protections because the State could seek appellate review of the intermediate court’s insufficiency determination.