The appellant, Gianluca Salvati, appealed his convictions for multiple drug offences, possession of proceeds of crime, and breach of a bail recognizance.
The Court of Appeal for Ontario dismissed the appeal.
The court upheld the trial judge's findings regarding constructive possession of drugs and proceeds, finding no misapprehension of evidence or reversal of the burden of proof.
On the breach of recognizance charge, the court found that an uncertified photocopy of the bail recognizance was properly admissible under the common law public or judicial documents exception to the hearsay rule, despite the trial judge having admitted it under the principled exception.
