Alfred Fabian Farias v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJuly 16, 2025
Docket04-24-00526-CR
StatusPublished

This text of Alfred Fabian Farias v. the State of Texas (Alfred Fabian Farias v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alfred Fabian Farias v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

04-24-00526-CR

Alfred Fabian FARIAS, Appellant

v.

The STATE of Texas, Appellee

From the County Court at Law No. 8, Bexar County, Texas Trial Court Nos. 731782 Honorable Mary Roman, Judge Presiding

Opinion by: H. Todd McCray, Justice

Sitting: Lori I. Valenzuela, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: July 16, 2025

AFFIRMED

Following a jury trial, Alfred Fabian Farias was convicted of two counts of Terroristic

Threats under Texas Penal Code Section 22.07(a)(2). Farias contends that the evidence was legally

insufficient to support his one conviction for making terroristic threats against complainant. We

affirm. 04-24-00526-CR

BACKGROUND

On April 9, 2024, Farias and complainant’s husband became involved in a verbal

altercation outside complainant’s home. Complainant was home at the time. She came to the front

porch, saw the confrontation between Farias and her husband, and called the police. According to

testimony, the encounter escalated, and Farias pulled out a knife and threatened “I am going to kill

both of you.” Complainant testified she felt threatened by Farias’s act of pulling the knife during

a heated argument. She testified Farias was about ten feet from her at the time and it would take

only “a few seconds” for him to reach her on the porch. She drew her gun in response—feeling

“extremely threatened” for both her and her husband’s life—believing that Farias was going to

attack them both.

In the underlying matter, Farias was convicted of making a terroristic threat against

complainant. Farias appeals.

STANDARD OF REVIEW

In determining whether the evidence is sufficient to support each element of a criminal

offense, we follow the Jackson v. Virginia legal-sufficiency standard, which requires a reviewing

court to view the evidence in the light most favorable to the verdict. Brooks v. State, 323 S.W.3d

893, 895 (Tex. Crim. App. 2010) (citing Jackson v. Virginia, 443 U.S. 307, 319 (1979)). This means

the reviewing court must give deference to the jury’s credibility and weight determinations, as the

jury is the sole judge of the witness’s credibility and the weight to be given their testimony. Brooks,

323 S.W.3d at 899. “[W]e examine all the evidence in the light most favorable to the verdict and

resolve all reasonable inferences from the evidence in favor of the jury’s verdict to determine

whether any rational trier of fact could have found the essential elements of the charged offense

-2- 04-24-00526-CR

beyond a reasonable doubt.” Briones v. State, 692 S.W.3d 828, 832 (Tex. App.—San Antonio 2024,

no pet.) (citing Nowlin v. State, 473 S.W.3d 312, 317 (Tex. Crim. App. 2015)).

“In reviewing the sufficiency of the evidence, we should look at events occurring before,

during[,] and after the commission of the offense and may rely on actions of the defendant which

show an understanding and common design to do the prohibited act.” Hooper v. State, 214 S.W.3d

9, 13 (Tex. Crim. App. 2007) (quotations omitted). “Intent can be inferred from the acts, words,

and conduct of the accused.” Dues v. State, 634 S.W.2d 304, 305 (Tex. Crim. App. 1982)

A victim’s reaction is also some evidence of the defendant’s intent. See Phillips v. State,

401 S.W.3d 282, 293 (Tex. App.—San Antonio 2013, pet. ref’d) (“The desired and sought after

reaction of the listener, regardless of whether the threat is carried out, constitutes some evidence

of the intent of the protagonist.”). “Each fact need not point directly and independently to the guilt

of the appellant, as long as the cumulative force of all the incriminating circumstances is sufficient

to support the conviction.” Cordova v. State, 698 S.W.2d 107, 111 (Tex. Crim. App.1985).

ANALYSIS

Farias asserts the evidence presented to the jury was legally insufficient to support the

judgment of conviction for terroristic threats against complainant. More specifically, Farias argues

the jury charge asked the jury to determine whether Farias “threatened serious bodily injury or

death to [complainant], with intent to place [complainant] in fear of imminent serious bodily

injury” and that such a finding was impossible given that complainant testified the threats were

communicated to her husband. We disagree.

Legal sufficiency is measured by the elements of the offense as defined by a hypothetically

correct jury charge. Villarreal v. State, 286 S.W.3d 321, 327 (Tex. Crim. App. 2009). Such a charge

accurately states the statutory requirements without improperly increasing the State’s burden or

-3- 04-24-00526-CR

restricting its theories of liability. Malik v. State, 953 S.W.2d 234, 240 (Tex. Crim. App. 1997).

This standard ensures that acquittals are reserved for actual evidentiary deficiencies rather than

technical jury charge errors. Id.

Under section 22.07(a)(2), “[a] person commits an offense if he threatens to commit any

offense involving violence to any person or property with intent to . . . place any person in fear of

imminent serious bodily injury.” TEX. PEN. CODE ANN. § 22.07(a)(2). The trial court correctly

charged the jury according to the statute. But Farias attempts to heighten the burden by construing

that language used in the charge and in the statute to mean the threat had to be communicated

directly to the complainant. The caselaw does not support his contention.

Because the plain language of section 22.07(a)(2) does not require the threat to be directly

communicated to the person receiving the threat, that is not an element of the offense. See Johnson

v. State, 710 S.W.3d 447, 453 (Tex. App.—Austin 2025, no pet. h.) (contrasting section 22.07(a)

with the harassment statute which “requires that the subject of the threat be the person receiving

the threat, a member of that person’s family, or the person’s property.”) (citing TEX. PEN. CODE

ANN. § 42.07(a)(2)); In the Matter of L.J.G., No. 03-99-00412-CV, 2000 WL 963163, at *8 (Tex.

App.—Austin July 13, 2000, no pet.) (not designated for publication) (holding section 22.07

“makes no distinction between direct and indirect threats”).

Likewise, 22.07(a)(2) does not require the threat to be perceived by complainant. See

Olivas v. State, 203 S.W.3d 341, 346 (Tex. Crim. App. 2006) (noting the terroristic-threat statute

implies “that one can threaten without necessarily placing another in fear of imminent bodily

injury. A logical inference from this is that “threatening,” as used in the Penal Code, does not

require that the intended victim perceive or receive the threat . . . .”) (emphasis added); see also In

re A.J.R.P., 441 S.W.3d 733, 738–39 (Tex. App.—San Antonio 2014, no pet.) (applying the

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

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Hooper v. State
214 S.W.3d 9 (Court of Criminal Appeals of Texas, 2007)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Dues v. State
634 S.W.2d 304 (Court of Criminal Appeals of Texas, 1982)
Olivas v. State
203 S.W.3d 341 (Court of Criminal Appeals of Texas, 2006)
Villarreal v. State
286 S.W.3d 321 (Court of Criminal Appeals of Texas, 2009)
Cordova v. State
698 S.W.2d 107 (Court of Criminal Appeals of Texas, 1985)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Robert Lyonell Phillips v. State
401 S.W.3d 282 (Court of Appeals of Texas, 2013)
Nowlin, Keiona Dashelle
473 S.W.3d 312 (Court of Criminal Appeals of Texas, 2015)
In re A.J.R.P.
441 S.W.3d 733 (Court of Appeals of Texas, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Alfred Fabian Farias v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alfred-fabian-farias-v-the-state-of-texas-texapp-2025.