Antonio Trevino v. the State of Texas, 13-19-00385-CR

Appellant Antonio Trevino was indicted for continuous sexual abuse of a child under 14 and sentenced to 48 years' imprisonment.
The child (S.G.) told her mother (J.G.) while J.G. was incarcerated that Trevino had molested her, saying he touched her "private areas" and "breast." J.G. was offered as the State's outcry witness.
Trevino objected at trial on hearsay grounds, arguing the outcry was too vague to meet art. 38.072's requirements; the trial court admitted J.G.'s testimony as an outcry statement.
Detective Ramos testified and introduced Trevino's recorded statement in which Trevino admitted multiple acts of sexual contact, digital and oral penetration, photographing S.G., and other abuse over several years.
S.G. testified at trial in detail about repeated abuse by Trevino from ages eight to twelve, corroborating the outcry and Detective Ramos's evidence.
The jury convicted Trevino of continuous sexual abuse of a child; on appeal Trevino challenged admission of J.G.'s outcry testimony as inadmissible hearsay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of J.G.'s testimony as an outcry under Tex. Crim. Proc. art. 38.072 (whether the outcry was sufficiently discernible or too vague)	State: J.G. was the properly designated outcry witness; S.G.'s statement described touching of "private areas" and "breast" over years and therefore was sufficiently discernible and within the exception.	Trevino: The statement was vague and constituted inadmissible hearsay not meeting the outcry exception.	Court affirmed: objection preserved; trial court did not abuse discretion—J.G.'s testimony was sufficiently specific and tracked statutory language; any error was harmless given S.G.'s detailed testimony and Trevino's confession.

Moses v. State, 105 S.W.3d 622 (Tex. Crim. App. 2003) (abuse-of-discretion standard for outcry witness designation)
Sanchez v. State, 354 S.W.3d 476 (Tex. Crim. App. 2011) (trial court's broad discretion in outcry admissibility)
Lankston v. State, 827 S.W.2d 907 (Tex. Crim. App. 1992) (hearsay objection phrasing can preserve article 38.072 issue)
Garcia v. State, 792 S.W.2d 88 (Tex. Crim. App. 1990) (outcry must be more than a general allusion to abuse)
Brown v. State, 189 S.W.3d 382 (Tex. App.—Texarkana 2006) (outcry sufficient when it tells how, when, and where and tracks statutory language)
Walters v. State, 247 S.W.3d 204 (Tex. Crim. App. 2007) (nonconstitutional error reviewed under Tex. R. App. P. 44.2(b))
Estrada v. State, 313 S.W.3d 274 (Tex. Crim. App. 2010) (improperly admitted evidence harmless when substantially similar evidence admitted without objection)