Armando Aguilar Garcia v. State

CourtCourt of Appeals of Texas
DecidedOctober 12, 2006
Docket01-05-01055-CR
StatusPublished

This text of Armando Aguilar Garcia v. State (Armando Aguilar Garcia v. State) 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
Armando Aguilar Garcia v. State, (Tex. Ct. App. 2006).

Opinion

Opinion issued October 12, 2006





In The

Court of Appeals

For The

First District of Texas



NO. 01-05-01055-CR



ARMANDO AGUILAR GARCIA, Appellant



V.



THE STATE OF TEXAS, Appellee



On Appeal from the 149th District Court

Brazoria County, Texas

Trial Court Cause No. 43780

MEMORANDUM OPINION

A jury convicted appellant, Armando Aguilar Garcia, of assault on a public servant. See Tex. Pen. Code Ann. § 22.01(a), (b)(1) (Vernon Supp. 2005). The trial court found true the enhancement allegations of three prior convictions--for robbery, burglary of a habitation, and retaliation--and assessed punishment at 25 years in prison. We determine (1) whether the evidence was legally and factually sufficient to support appellant's conviction for assault on a public servant, (2) whether the trial court erred by not including in the jury instructions the lesser-included-offense charges of misdemeanor resisting arrest and misdemeanor assault, and (3) whether the trial court reversibly erred in finding the enhancement allegations true when the State failed properly to authenticate the penitentiary packet admitted into evidence during the punishment phase of the trial. We affirm.

Background

On September 20, 2002, Officer Shawn Gilcrease, a patrol officer in the Alvin Police Department, was dispatched to 319 West Adoue in reference to a domestic disturbance. Officer Gilcrease arrived at the home around 5:30 p.m. and was greeted by Josephine Garcia, appellant's sister. She told the officer that appellant was inside and gave Officer Gilcrease permission to enter the house. Officer Gilcrease told appellant why he had been called over to the house and asked for any information about the incident. After having spoken with appellant and several family members, Officer Gilcrease decided to arrest appellant for assault by threat, family violence.

Appellant was initially compliant with Officer Gilcrease as he was handcuffed and searched. When Officers Gilcrease and another officer, Officer Dowd, attempted to escort appellant to a patrol car, however, appellant resisted, jumping up and down and attempting to break free of the officers' grasp. He backed his feet up to prevent being taken outside and kicked his legs up at the door to prevent the officers from opening the door. At this point, appellant was able to break free of the officers' grasp. Officer Gilcrease then bent appellant over the couch in order better to restrain him. Throughout this fracas, appellant was using profanities toward the officers, and he then began kicking at them. Due to appellant's aggressive behavior, another officer at the scene, Officer Kelly, sprayed appellant with pepper spray. While the effect of the pepper spray initially caused appellant to calm down, he resumed kicking at the door once the officers tried to escort him to the patrol car. Finally, the officers managed to remove appellant from the house. Appellant lunged at Officer Dowd, causing Officer Dowd, Officer Gilcrease, and appellant to tumble out of the front door and onto the concrete porch. The officers then walked appellant toward the patrol car. Although appellant was no longer kicking or resisting, he continued to use profanities toward the officers. As appellant neared the patrol car, he spat on it.

At this point, appellant turned his aggression toward Officer Gilcrease and attempted to spit on him. Officer Gilcrease grabbed appellant by the back of the neck and bent him to the ground in an effort to keep appellant from spitting on him. Appellant, with his back to Officer Gilcrease and bent over at the waist, kicked his right leg back, striking Officer Gilcrease near the groin on the upper thigh. Officer Gilcrease and the other officers then took appellant to the ground and sprayed him with pepper spray again. The pepper spray subdued appellant enough for the officers to place him in the back of the patrol car.

Before the trial court submitted the case to the jury for deliberation, appellant requested inclusion of two lesser-included offenses--resisting arrest and misdemeanor assault--in the jury charge. The trial court denied the request. At the punishment stage of the trial, appellant objected to State's Exhibit 7, a penitentiary packet containing judgments of conviction for aggravated robbery and burglary of a habitation, as a means of proving appellant's prior convictions for sentencing enhancement purposes. In support of his objection, appellant argued that because the State's fingerprint expert could not positively match the fingerprints in the penitentiary packet with those of appellant, the prior convictions were not properly authenticated and should not have been admitted for enhancement purposes. The trial court overruled this objection and allowed the penitentiary packet to be admitted. The court determined that these two enhancements, plus one other enhancement for the felony of retaliation, were true. The trial court then assessed appellant's punishment at 25 years in prison based on his assault on a public servant and the three enhancement paragraphs. (1)

Legal and Factual Sufficiency

In his first and second points of error, appellant challenges the legal and factual sufficiency of the evidence to prove that he struck Officer Gilcrease with his foot and thereby caused the officer bodily injury.

A. Standard of Review

A legal-sufficiency challenge requires us to determine whether, after viewing the evidence in the light most favorable to the verdict, any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt. Johnson v. State, 23 S.W.3d 1, 7 (Tex. Crim. App. 2000); Howley v. State, 943 S.W.2d 152, 155 (Tex. App.--Houston [1st Dist.] 1997, no pet.).

When conducting a factual-sufficiency review, we view all of the evidence in a neutral light and set the verdict aside only if the evidence is so weak that the verdict is clearly wrong and manifestly unjust or if the contrary evidence is so strong that the standard of proof of beyond a reasonable doubt could not have been met. Escamilla v. State, 143 S.W.3d 814, 817 (Tex. Crim. App. 2004) (citing Zuniga v. State, 144 S.W.3d 477, 483 (Tex. Crim. App. 2004)). In conducting a factual-sufficiency review, we must discuss the evidence that, according to the appellant, most undermines the jury's verdict.

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