Gustavo Tijerina Sandoval v. the State of Texas

CourtCourt of Appeals of Texas
DecidedMarch 6, 2025
Docket13-18-00392-CR
StatusPublished

This text of Gustavo Tijerina Sandoval v. the State of Texas (Gustavo Tijerina Sandoval 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
Gustavo Tijerina Sandoval v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

NUMBER 13-18-00392-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

GUSTAVO TIJERINA SANDOVAL, Appellant,

v.

THE STATE OF TEXAS, Appellee.

ON APPEAL FROM THE 197TH DISTRICT COURT OF CAMERON COUNTY, TEXAS

MEMORANDUM OPINION

Before Chief Justice Tijerina and Justices Peña and West Memorandum Opinion by Justice West

Appellant, Gustavo Tijerina Sandoval, was found guilty by a jury of capital murder

and attempted capital murder. See TEX. PENAL CODE ANN. §§ 15.01(a), 19.03(a)(2).

Appellant was sentenced to the death penalty for the capital murder and life imprisonment

for the attempted capital murder. This appeal relates solely to appellant’s conviction for attempted capital murder. 1 Appellant raises fourteen points of error, which we reorder for

clarity. Finding no reversible error, we affirm.

I. SUFFICIENCY OF THE EVIDENCE

By his first issue, appellant argues that there is insufficient evidence to support his

conviction.

A. Background

Appellant was charged, in a two-count indictment, with (1) capital murder of Javier

Vega Jr. (“Junior”) and (2) attempted capital murder of Javier Vega Sr. (“Senior”). On

August 3, 2014, Junior (an off-duty border patrol agent) and his family decided to go

fishing. Junior drove with his wife, Paola Brown; their two children, Jarod and Jiovanni;

and Jiovanni’s friend, Aric Garcia. Senior and Marie Vega, Junior’s mother, drove in a

separate vehicle.

Evidence adduced at trial generally established the following. On route to the

family’s fishing spot, Senior and Marie noticed two men in a red SUV parked on the side

of the road. The red SUV followed the cars driven by the Vega family and stopped about

thirty yards from where the family set up to fish. The SUV stayed for a few seconds then

drove away. The SUV returned about ten to twenty minutes later, two men jumped out,

yelled at the Vega family, and began shooting at them. Witnesses testified that appellant

shot Junior, and both appellant and his codefendant, Ismael Hernandez Vallejo, shot

toward Senior. Junior and Senior returned fire, causing appellant and Vallejo to flee.

1 Sandoval’s capital murder conviction was automatically appealed to the Texas Court of Criminal

Appeals, and the Court affirmed his conviction and sentence. See Sandoval v. State, 665 S.W.3d 496, 506 (Tex. Crim. App. 2022); see also TEX. CODE CRIM. PRO. ANN. art. 37.071(h) (providing that a defendant’s “judgment of conviction and sentence of death” are automatically reviewed by the CCA). 2 Senior sustained a gunshot wound to his gluteal region, and Junior sustained a fatal

gunshot wound to the chest.

Appellant and Vallejo were later found hiding together in a garage from law

enforcement, and the two were arrested around 2:00 a.m. the next morning. That same

day, appellant was interviewed twice by Texas Rangers Donato Vela and Patrick

O’Connor at the Willacy County Sheriff’s Office. Transcripts of the interviews were

admitted into evidence. In the interviews, appellant claimed that (1) he drove a red

suburban to go fishing; (2) two people shot at him and Vallejo when they arrived at the

fishing location; (3) he “fired back,” and was “guilty”; (4) he and Vallejo fled shortly

thereafter; (5) and he dropped a .45 caliber gun used in the shootout “in the brush” as

they fled. Appellant also admitted that he and Vallejo planned to rob the Vega family to

pay a debt:

Ranger Vela: [W]hen you arrived . . . . Were you and [Vallejo] together?

Appellant: (Nods in affirmative) Yes, we were in agreement; we were both in agreement.

Ranger Vela: In agreement for what?

Appellant: To go there; to go there.

Ranger Vela: To-o-o. . .

Appellant: To fish and all that.

....

Ranger Vela: But, when you say: “Were in agreement[.]” You were in agreement to go and rob a person or you were going to shoot someone, or what? What was it that you were in agreement to?

Appellant: To go there with them. Not to kill anybody or anything.

3 Ranger Vela: Not to kill anybody?

Appellant: No.

Ranger Vela: Only to rob a person?

Appellant: (moment of silence) Because they threatened me.

Ranger Vela: Who threatened you, Gustavo?

Appellant: One from . . . Weslaco; that if I didn’t give them the truck, they were going to kill my father and my mother (unintelligible).

Ranger Vela: You owed them some money?

Appellant: (Nods in the affirmative)

Appellant explained to the Rangers that he owed $3,500 to people who had threatened

to kill his parents and his wife.

Lastly, the State introduced physical evidence linking appellant to the scene of the

crime. Appellant’s hands were swabbed for gunshot residue, and the test results came

back positive, indicating he had recently fired a gun. A .45 caliber pistol was found near

the scene of appellant’s arrest, and four .45 caliber casings were found at the crime

scene. The State’s firearm expert testified a .45 caliber bullet fragment was recovered

from Junior’s body, though he could not confirm the bullet was fired from the recovered

pistol.

B. Standard of Review & Applicable Law

In reviewing sufficiency of the evidence, we consider all the evidence presented in

the light most favorable to the verdict to determine whether the trial court was justified in

finding guilt beyond a reasonable doubt. Braughton v. State, 569 S.W.3d 592, 607–08

(Tex. Crim. App. 2018); Brooks v. State, 323 S.W.3d 893, 899 (Tex. Crim. App. 2010) 4 (plurality op.) (citing Jackson v. Virginia, 443 U.S. 307, 319 (1979)). We defer to the jury’s

role as the factfinder, which includes “resolving conflicts in the testimony, weighing the

evidence, and drawing reasonable inferences from basic facts.” Murray v. State, 457

S.W.3d 446, 448 (Tex. Crim. App. 2015).

“The sufficiency of the evidence is measured by comparing the evidence produced

at trial to ‘the essential elements of the offense as defined by the hypothetically correct

jury charge.’” Curlee v. State, 620 S.W.3d 767, 778 (Tex. Crim. App. 2021) (quoting Malik

v. State, 953 S.W.2d 234, 240 (Tex. Crim. App. 1997)). “A hypothetically correct jury

charge ‘accurately sets out the law, is authorized by the indictment, does not

unnecessarily increase the State’s burden of proof or unnecessarily restrict the State’s

theories of liability, and adequately describes the particular offense for which the

defendant was tried.’” Id. (quoting Malik, 953 S.W.2d at 240).

A person commits murder if he intentionally or knowingly causes the death of an

individual. TEX. PENAL CODE ANN. § 19.02(b)(1). 2 A person commits capital murder if the

person intentionally commits murder in the course of committing or attempting to commit

robbery. Id. §§ 19.02(b)(1), 19.03(a)(2). A person commits an attempt of a criminal

2 “Intentional” and “knowing” conduct are defined in the penal code as:

(a) A person acts intentionally, or with intent, with respect to the nature of his conduct or to a result of his conduct when it is his conscious objective or desire to engage in the conduct or cause the result.

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