In the Interest of H.R.J., J.G.J., III, T.J.P., and L.P., Children v. the State of Texas

Texas Court of Appeals, 4th District (San Antonio)·Decided April 15, 2026·No. 04-25-00641-CV·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-25-00641-CV

IN THE INTEREST OF H.R.J., J.G.J., T.J.P., and L.P., Children

From the 365th Judicial District Court, Zavala County, Texas Trial Court No. 24-02-15329-ZCVAJA Honorable Amado J. Abascal III, Judge Presiding

Opinion by: Irene Rios, Justice

Sitting: Irene Rios, Justice Adrian A. Spears II, Justice Velia J. Meza, Justice

Delivered and Filed: April 15, 2026 AFFIRMED Appellant Mother appeals the trial court’s order terminating her parental rights to her children, H.R.J., J.G.J., T.J.P., and L.P. 1 In her first and second issues, Mother challenges the sufficiency of the evidence supporting termination of her parental rights under statutory grounds (D) and (E). In her third issue, Mother challenges the sufficiency of the evidence supporting the trial court’s finding that termination was in the children’s best interests. We affirm.

1 To protect the identity of minor children in an appeal from an order terminating parental rights, we refer to the children’s mother as “Mother,” we refer to L.P.’s father as “Father J.M.,” and we refer to the children using their initials or as “the children.” See TEX. FAM. CODE ANN. § 109.002(d); TEX. R. APP. P. 9.8(b)(2). The trial court’s order also terminated the fathers’ rights to their respective children; however, the fathers do not appeal.

BACKGROUND

The Department became involved in the underlying case when it received a referral Mother was abusing drugs and had left L.P. with his father while there was a protective order in place protecting L.P. from the father. At the time, Mother had already had her children removed by the Department three times because of her drug addiction. Initially, the Department could not locate Mother and discovered the older three children were staying with their maternal aunt (“Aunt”) and uncle (“Uncle”). The Department sought removal of the children after Mother tested positive for illegal drugs.

On February 22, 2024, the Department filed a petition seeking termination of Mother’s parental rights. The trial court held a four-day bench trial on July 18, 2025, September 9, 2025, September 24, 2025, and concluding on October 2, 2025. The trial court heard testimony from Veronica Orosco, the Department’s removal investigator; Carlos Piliado, a permanency specialist with the Department; 2 Father J.M., L.P.’s father; Aunt; Lorenzo Ortiz, Mother’s counselor; and Mother.

On March 25, 2024, the trial court signed an order terminating Mother’s parental rights to the children. The trial court terminated Mother’s parental rights based on statutory grounds (D) and (E) in subsection 161.001(b)(1) of the Texas Family Code. See TEX. FAM. CODE ANN. §§ 161.001(b)(1)(D), (E). The trial court also found it was in the children’s best interests to terminate Mother’s parental rights. See id. § 161.001(b)(2). Mother appeals.

2 Carlos Piliado is employed by SJRC Texas Belong, a community-based care provider contracted by the Department. We refer to Piliado as the Department’s caseworker because SJRC Texas Belong is a contractor working on behalf of the Department.

STATUTORY REQUIREMENTS AND STANDARD OF REVIEW To terminate parental rights pursuant to section 161.001 of the Texas Family Code, the Department has the burden to prove by clear and convincing evidence: (1) one of the predicate grounds in subsection 161.001(b)(1); and (2) that termination is in the best interest of the child. TEX. FAM. CODE ANN. § 161.001(b). Clear and convincing evidence requires “proof that will produce in the mind of the trier of fact a firm belief or conviction as to the truth of the allegations sought to be established.” Id. § 101.007.

When reviewing the sufficiency of the evidence, we apply well-established standards of review. See id. §§ 101.007, 161.206(a); In re H.R.M., 209 S.W.3d 105, 108 (Tex. 2006) (conducting a factual sufficiency review); In re J.P.B., 180 S.W.3d 570, 573 (Tex. 2005) (conducting a legal sufficiency review).

“In reviewing the legal sufficiency of the evidence to support the termination of parental rights, we must ‘look at all the evidence in the light most favorable to the finding to determine whether a reasonable trier of fact could have formed a firm belief or conviction that its finding was true.’” In re J.L.B., No. 04-17-00364-CV, 2017 WL 4942855, at *2 (Tex. App.—San Antonio Nov. 1, 2017, pet. denied) (mem. op.) (quoting In re J.F.C., 96 S.W.3d 256, 266 (Tex. 2002)). “[A] reviewing court must assume that the factfinder resolved disputed facts in favor of its finding if a reasonable factfinder could do so.” J.F.C., 96 S.W.3d at 266. “A corollary to this requirement is that a [reviewing] court should disregard all evidence that a reasonable factfinder could have disbelieved or found to have been incredible.” Id.

“In reviewing the factual sufficiency of the evidence to support the termination of parental rights, we ‘must give due consideration to evidence that the factfinder could reasonably have found to be clear and convincing.’” J.L.B., 2017 WL 4942855, at *2 (quoting J.F.C., 96 S.W.3d at 266).

“A [reviewing court] should consider whether disputed evidence is such that a reasonable factfinder could not have resolved that disputed evidence in favor of its finding.” J.F.C., 96 S.W.3d at 266. “The [reviewing] court must hold the evidence to be factually insufficient if, in light of the entire record, the disputed evidence contrary to the judgment is so significant that a reasonable factfinder could not have resolved that disputed evidence in favor of the ultimate finding.” In re M.T.C., No. 04-16-00548-CV, 2017 WL 603634, at *2 (Tex. App.—San Antonio Feb. 15, 2017, no pet.) (mem. op.).

Further, in a bench trial, the trial court is the sole judge of the credibility of witnesses and the weight to be given their testimony. In re J.F.-G., 627 S.W.3d 304, 312, 317 (Tex. 2021). This is because “the trial judge is best able to observe and assess the witnesses’ demeanor and credibility, and to sense the ‘forces, powers, and influences’ that may not be apparent from merely reading the record on appeal.” Coburn v. Moreland, 433 S.W.3d 809, 823 (Tex. App.— Austin 2014, no pet.) (quoting In re A.L.E., 279 S.W.3d 424, 427 (Tex. App.—Houston [14th Dist.] 2009, no pet.)). We, therefore, defer to the trial court’s factual determinations and judgment regarding credibility. J.F.-G., 627 S.W.3d at 312; see also In re R.R.A., 687 S.W.3d 269, 279 n.50 (Tex. 2024) (“Reviewing courts, however, must defer to the factfinder’s judgment as to the credibility of the witnesses and the weight to give their testimony, including reasonable and logical inferences from the evidence.”).

STATUTORY GROUNDS FOR TERMINATION In her first and second issues, Mother argues there is insufficient evidence to support the trial court’s findings under statutory grounds (D) and (E).

Only one predicate ground finding under section 161.001(b)(1) is necessary to support a termination judgment when there is also a finding that termination is in the child’s best interest.

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In the Interest of H.R.J., J.G.J., III, T.J.P., and L.P., Children v. the State of Texas, (Tex. Ct. App. 2026).

In the Interest of H.R.J., J.G.J., III, T.J.P., and L.P., Children v. the State of Texas (In the Interest of H.R.J., J.G.J., III, T.J.P., and L.P., Children v. the State of Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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