Geronimo Scott Aguilar v. State, 02-15-00373-CR

Background

Aguilar, a former youth/ministry leader, was convicted after a 2014 trial for multiple sexual offenses involving a complainant who was 13–14 in 1996–1997; jury sentenced him to concurrent long prison terms.
Allegations included repeated sexual acts beginning when the complainant was 13; additional misconduct years later involved extramarital affairs and an alleged inappropriate relationship with a different minor (C.H.).
The complainant delayed reporting until she learned another woman (C.H.) intended to come forward about Aguilar; C.H. testified at trial about her relationship with Aguilar.
Defense objected at trial to admission of extraneous-act evidence and certain testimony as "backdoor hearsay." The trial court admitted the contested evidence or overruled objections at various points.
On appeal Aguilar raised four evidentiary issues: three challenging admission of extraneous-bad-act evidence and one alleging improper backdoor hearsay.
The Court of Appeals affirmed, holding most complaints were not preserved (untimely, general, or not renewed) or were harmless because similar evidence came in without objection.

Issues

Issue	Plaintiff's Argument (Aguilar)	Defendant's Argument (State)	Held
1. Admission of testimony that complainant came forward after learning C.H. would come forward	Aguilar: this evidence was improper and prejudicial extraneous evidence	State: C.H.’s testimony was admitted and more detailed; any error cured	Overruled—error not preserved/harmless because similar evidence admitted without objection
2. Admission of testimony about Aguilar’s inappropriate relationship with C.H.	Aguilar: testimony of C.H. and godfather constituted improper extraneous-act evidence and hearsay	State: Questions were proper rebuttal to Aguilar’s testimony denying prior accusations; much testimony came in without objection	Overruled—most objections were not specific or not pursued; evidence came in elsewhere without objection
3. Admission of details about Aguilar’s extramarital affairs (multiple witnesses)	Aguilar: affairs testimony exceeded scope, irrelevant, prejudicial extraneous-act evidence	State: defense opened door by impeaching/bias inquiries and Aguilar admitted affairs on direct/cross; some testimony admitted without objection	Overruled—either no error or error not preserved; similar evidence came in without objection
4. Admission of Lou’s testimony (alleged backdoor hearsay corroborating complainant)	Aguilar: Lou’s testimony about telling complainant’s mother to report was backdoor hearsay and improperly corroborative	State: the substance was duplicated by later testimony (Pastor Zaragoza) and other testimony came in without objection	Overruled—any error harmless because substantially the same facts were later admitted without objection

Key Cases Cited

Martinez v. State, 327 S.W.3d 727 (Tex. Crim. App. 2010) (abuse-of-discretion standard for evidentiary rulings)
De La Paz v. State, 279 S.W.3d 336 (Tex. Crim. App. 2009) (review standard for evidentiary rulings)
Kirk v. State, 421 S.W.3d 772 (Tex. App.—Fort Worth 2014) (presumption that relevant evidence is more probative than prejudicial)
Moses v. State, 105 S.W.3d 622 (Tex. Crim. App. 2003) (deference where ruling within zone of reasonable disagreement)
Douds v. State, 472 S.W.3d 670 (Tex. Crim. App. 2015) (preservation rule requiring specific timely objection)
Fuller v. State, 253 S.W.3d 220 (Tex. Crim. App. 2008) (failure to object waives appellate review of witness testimony)
Valle v. State, 109 S.W.3d 500 (Tex. Crim. App. 2003) (error cured when same evidence later admitted without objection)
Mendez v. State, 138 S.W.3d 334 (Tex. Crim. App. 2004) (most complaints forfeited for failure to comply with preservation rules)
Ford v. State, 305 S.W.3d 530 (Tex. Crim. App. 2009) (appellate court should not consider unpreserved issues)