Reynaldo Rios Jr. v. the State of Texas

CourtCourt of Appeals of Texas
DecidedAugust 15, 2024
Docket13-23-00097-CR
StatusPublished

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Bluebook
Reynaldo Rios Jr. v. the State of Texas, (Tex. Ct. App. 2024).

Opinion

NUMBER 13-23-00097-CR

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

REYNALDO RIOS JR., Appellant,

v.

THE STATE OF TEXAS, Appellee.

ON APPEAL FROM THE 117TH DISTRICT COURT OF NUECES COUNTY, TEXAS

MEMORANDUM OPINION Before Chief Justice Contreras and Justices Tijerina and Peña Memorandum Opinion by Justice Tijerina

A jury convicted appellant Reynaldo Rios Jr. of first-degree arson of a habitation,

a first-degree felony. See TEX. PENAL CODE ANN. § 28.02. The jury assessed punishment

for a period of fifty-five years of imprisonment. Appellant argues the State failed to prove

all the elements required to convict him of arson. We affirm. I. STANDARD OF REVIEW AND APPLICABLE LAW

In a sufficiency review, we consider all the evidence in the light most favorable to

the verdict and determine whether any rational fact finder could have found the essential

elements of the crime beyond a reasonable doubt based on the evidence and reasonable

inferences from that evidence. Whatley v. State, 445 S.W.3d 159, 166 (Tex. Crim. App.

2014); Brooks v. State, 323 S.W.3d 893, 898–99 (Tex. Crim. App. 2010) (plurality op.).

Sufficient evidence exists if “the inferences necessary to establish guilt are reasonable

based upon the cumulative force of all the evidence when considered in the light most

favorable to the verdict.” Wise v. State, 364 S.W.3d 900, 903 (Tex. Crim. App. 2012). The

fact finder is the exclusive judge of the facts, the credibility of witnesses, and the weight

to be given to their testimony. Brooks, 323 S.W.3d at 899.

We measure the sufficiency of the evidence in reference to 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); Malik v. State, 953 S.W.2d 234, 240 (Tex. Crim. App.

1997). “Such a charge [is] one that 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.” Villarreal, 286 S.W.3d at 327 (quoting Malik, 953 S.W.2d

at 240). The “law as authorized by the indictment” includes the statutory elements of the

offense and those elements “as modified by the indictment.” Curry v. State, 30 S.W.3d

394, 404 (Tex. Crim. App. 2000). As applicable here, the State had the burden to prove

beyond a reasonable doubt that (1) appellant intentionally, knowingly, or recklessly

2 started a fire by igniting a couch, (2) with the intent to destroy or damage a habitation,

and (3) knew that the habitation had located within it, property, namely furniture and

clothes, belonging to another. See TEX. PENAL CODE ANN. § 28.02(a)(2)(E). Appellant only

challenges the last element.

II. THE EVIDENCE

On August 2, 2019, the Robstown Fire Department responded to a call about a

burning house in Nueces County. When the firefighters arrived on the scene, the house

was in flames. Lupe Villarreal, a firefighter on the scene, testified that the fire must have

started around twenty or thirty minutes prior to his arrival. The house was “completely

destroyed” and “completely burned down” after firefighters spent several hours putting

out the fire. Dana Richardson, a sergeant and investigator with the Nueces County

Sheriff’s Office on the date of the incident, testified that when he inspected the house the

next day, it was “totally destroyed,” and the house next door was uninhabitable due to

smoke, fire damage, and water damage.

Rosa Anna Garcia, appellant’s wife, testified that her house destroyed in the fire

had been in her family for several generations, which her parents gifted to her in 2000.

Garcia stated that she met appellant in 2015, and the couple married in 2017. According

to Garcia, appellant did not purchase things in the house because he spent his money on

beer and child support. Garcia stated that appellant had problems with drinking that got

worse over time, and he was physical with Garcia on one occasion a few days before the

fire. Garcia testified that appellant was upset with her children, he threw her children’s

PlayStation on the floor, and he pushed Garcia to the wall when she questioned him about

3 what he had done. Garcia called the police to remove appellant from her house, and

according to Garcia, the police stated that they could not remove him because, due to

their marriage, the police considered the house as belonging to Garcia and appellant.

Garcia testified that after telling appellant it was her house, he refused to leave; therefore,

Garcia and her children spent the night next door at her parents’ house. Garcia stated

that the house contained all of her and her children’s belongings, including her furniture

and clothes, which were destroyed in the fire.

On the day of the fire, Garcia had the electricity, gas, and water turned off in her

house, which appeared to upset appellant. About thirty-four minutes before the firefighters

arrived at the scene, appellant sent Garcia a text message saying, “[h]opefully going to

burn it all down.” Garcia replied, “[w]hat are you going to burn down?” Appellant said,

“[m]y eyebrows.” Appellant then texted, “[y]our house is on fire.” Garcia soon arrived at

the scene to see her entire home engulfed in flames. Garcia testified that she lost

everything in the fire, including her clothes, her children’s clothes, furniture, and photo

albums; and all she had left were “the clothes on [her] back.” Evidence was also presented

that the family’s dog perished in the fire.

Appellant was arrested and taken to the criminal investigation division for a

custodial interview conducted by Richardson and State Fire Marshall, Greg Houston. 1

Richardson read appellant his Miranda rights and began the interview. Richardson

testified that appellant was not intoxicated and had “use of his mental and physical

capabilities.” During the interview, appellant admitted to starting the fire by lighting a

1 Houston was not available to testify at trial because he had unfortunately passed away.

4 couch on fire with a barbeque lighter. Appellant knew that the house was not insured.

Appellant then made statements referring to burning his property in the house by saying,

“I can burn my own stuff if I want to,” and, “today I just, you know what, I just burned up

all my stuff.” However, appellant also acknowledged that the house belonged to Garcia.

For example, when asked whose house it was, appellant said, “it’s hers,” and when

drawing a diagram of the house, he described one of the rooms as Garcia’s bedroom.

Appellant stated that Garcia and her ex-husband had taken out a mortgage on the house

before he met Garcia. Appellant also made statements regarding his motive when he

said, “well . . . all day today my wife kept picking at me,” and “what set me off, she just

went and turned off everything, no light, no water.”

The jury convicted appellant of arson of a habitation. This appeal followed.

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Related

Curry v. State
30 S.W.3d 394 (Court of Criminal Appeals of Texas, 2000)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Villarreal v. State
286 S.W.3d 321 (Court of Criminal Appeals of Texas, 2009)
Brooks v. State
323 S.W.3d 893 (Court of Criminal Appeals of Texas, 2010)
Wise v. State
364 S.W.3d 900 (Court of Criminal Appeals of Texas, 2012)
Whatley v. State
445 S.W.3d 159 (Court of Criminal Appeals of Texas, 2014)
Tate v. State
500 S.W.3d 410 (Court of Criminal Appeals of Texas, 2016)

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