Eduardo Santillana Garza v. the State of Texas

Court of Appeals of Texas·Decided September 23, 2025·No. 08-24-00146-CR·Published

Opinion

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS

in which the State alleged that he shot Abelardo Moreno while committing a theft. The trial court sentenced Garza to life in prison without the possibility of parole for the capital murder conviction and 40 years’ imprisonment for the aggravated robbery conviction, with the sentences to run concurrently. 1 On appeal, Garza contends the trial court erred by denying his request for a lesser-included instruction on the offenses of burglary of a building and burglary of a habitation. Finding no error, we affirm the trial court’s judgment.

I. FACTUAL BACKGROUND

Miguel Rivera, Sr. owned a ranch in Tornillo, Texas with several structures on it, including a trailer where he resided prior to his death. At trial, his son, Miguel Rivera, Jr., testified that Rivera, Sr. had hired Garza two or three months before the shooting to assist him with remodeling his trailer, and as part of Garza’s compensation, he allowed Garza and his girlfriend to live in a separate trailer on the property. Rivera, Jr. recalled that his father terminated Garza several days before the shooting because tools had begun to disappear from the property and Garza would frequently fail to appear for work. Rivera, Jr. helped his father ensure Garza and his girlfriend left the property, and he recalled that shortly thereafter, on July 9 and 10, 2018, Garza sent Rivera, Sr. a series of text messages expressing anger over being forced to leave. 2

1 “An individual adjudged guilty of a capital felony in a case in which the state does not seek the death penalty shall be punished by imprisonment in the Texas Department of Criminal Justice for . . . life without parole, if the individual committed the offense when 18 years of age or older.” Tex. Pen. Code Ann. § 12.31(a)(2), 2 The text messages, which were introduced in evidence at trial, stated:

What the hell am I being kicked out for . . .

So was there a good reason to kick me out the way u did . . . w[ith]out any good explanation . . . that was a cowardly way of getting me out. [A]nd my lady was asking me if the futon u gave her if she can go for it[.]

Rivera, Sr. thereafter hired Abelardo Moreno to assist him with the remodel. Moreno was aware that Rivera, Sr. had terminated another worker who had been living on the property a “few days” before he was hired, but Moreno had never met or spoken with Garza.

A. The shootings At trial, Moreno testified that he was at Rivera, Sr.’s ranch on the morning of July 25, 2018, to assist him with various chores, including cleaning the inside of his black Nissan truck. After cleaning the truck, Moreno followed Rivera, Sr. into an older adobe house on the property, which he believed had previously been used as a residence but was now being used primarily for storage. As they entered the house, Moreno witnessed Rivera, Sr. suddenly raise his hands and fall to the ground. Moreno thereafter observed a man sitting down in the house dressed all in black with a mask covering his entire face. He recalled the man was pointing a gun, which he described as a black revolver, at him. On either side of the man, Moreno saw a black “tool” bag with handles.

Although Moreno asked him not to shoot, the man shot Moreno in the neck and told him not to get up or he would shoot him again. When the man asked if anyone else was on the property, Moreno replied in the negative. The man then asked Moreno where the keys were to the “little truck” parked outside, which Moreno understood to mean Rivera, Sr.’s black Nissan. Moreno told him the keys were in the ignition. The man told Moreno not to get up until he could no longer hear the sound of the truck. The man took Moreno’s cell phone and left the house. According to Moreno, no one else was in the house at the time of the shootings.

I’m going to keep at it and at it until I am told why the hell I got kicked out in the way I did . . . and when I can get the futon u gave my lady. Not for me. But I hurt my back taking it out [of] ur house and u said it was hers.

Moreno testified that he initially thought the shooter might have been Rivera, Jr. because the man was the same approximate size, but after hearing his voice, Moreno “realized that it was not him.” However, Moreno did not recognize the man or his voice.

After the man left, Moreno used Rivera, Sr.’s cell phone to call Rivera, Sr.’s daughter—

the first number that he found in the phone—to alert her to the shooting. Cell phone records later obtained by police indicated the call occurred at 8:36 that morning. Because the daughter did not know the address of the ranch, she called Rivera, Jr. for help.

Rivera, Jr. testified that he was at the home of his friend, Victor Gandara, in Fabens, Texas, approximately 15 miles away when he received his sister’s call. He drove with Gandara to the ranch, calling 911 on the way. When he arrived, he heard Moreno calling for him inside the adobe home. Upon entering, he saw his father lying in a pool of blood with what appeared to be a gunshot wound to his head. He noticed at the time that his father’s Nissan truck was missing.

Paramedics arrived shortly thereafter and transported both Moreno and Rivera, Sr. to the hospital where Rivera, Sr. was pronounced dead. An autopsy revealed that Rivera, Sr. died of a gunshot wound to his forehead and that the barrel of the gun was either in contact with or within an inch or two of his forehead when it was fired. The medical examiner’s office ruled Rivera, Sr.’s death a homicide by a gunshot wound to the head. Moreno was treated at the hospital for his gunshot wound and was still experiencing difficulties with his throat at the time of trial.

B. Law enforcement’s investigation After law enforcement officers arrived at the scene, Rivera, Jr. informed them that he suspected Garza may have been the shooter based on Garza’s prior dealings with his father and the text messages he had sent him. Rivera, Jr. also informed them that Garza was the only person he knew who had “an issue” with his father.

That same morning, the police located Rivera, Sr.’s Nissan truck at an apartment complex in Fabens. After speaking with individuals at the apartment complex, the police determined that Garza was at the home of Gloria Chavez, approximately a half mile away.

Chavez testified at trial that Garza was a friend of her neighbor, Saul Cortez, and that she had previously interacted with Garza when he visited Cortez. She recalled that at approximately 10:30 or 11:00 a.m. the morning of the shooting, she saw Garza walking out of Cortez’s backyard. Because Cortez and Garza were friends, she did not find this unusual. Chavez recalled that she and Garza thereafter began a conversation, and he was sitting on her front porch when deputies arrived later that day to arrest him.

That same morning, law enforcement officers conducted a full search of Cortez’s property.

They discovered a box in Cortez’s backyard containing a black bag that matched the description of the bags Moreno reported seeing in the adobe home next to the shooter. 3 The bag contained a black Ruger .22-caliber revolver with an eagle emblem on the handle as well as two fired casings and four unfired rounds. The bag also contained a Sony car stereo, several knives, a red bandanna, and Crown Royal bags—of the type Rivera, Jr. testified his father frequently used to store items.

A firearm expert testified at trial that he compared the ammunition remaining in the revolver with the projectiles recovered from Rivera, Sr.’s body and from Moreno’s neck. Although the results were inconclusive, the expert testified that the recovered projectiles were .22-caliber bullets “similar” to the ones found in the revolver. He concluded that it was therefore possible that the revolver had been used to shoot Rivera, Sr. and Moreno.

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Eduardo Santillana Garza v. the State of Texas, (Tex. Ct. App. 2025).

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