The following article summarizes the Second Appellate District’s ruling in a mandatory appeal of a first-degree murder conviction wherein defendant challenged sufficiency of the evidence to show he committed the murders with premeditation and deliberation.
The Gist of this Article: First degree premeditated murder conviction of four others affirmed by Second Appellate District. The following summary presents a good explanation of the elements of premeditation and deliberation in murder.
The crime at issue was unbelievable. On July 13, 2002, the bodies of Miguel Ruiz (also known as Mike), Maritza Trejo, Ana Martinez and Jasmine Ruiz were found in a Whittier home they shared.
Medical examiners conducted autopsies of each of the four victims. Mike had multiple sharp-force injuries on his body, including in the neck and back. The cause of death was a slicing wound in the front of his neck, which severed his jugular veins. He had no defensive wounds. The wound to his neck was consistent with an attack from behind.
Maritza was stabbed 31 times and cut 14 times. Some injuries were consistent with a single-edge knife, while others were consistent with a double-edge knife. She had at least five fatal wounds – on her neck, chest and back.
Ana suffered two fatal sharp-force wounds to her neck. The wounds were consistent with an attacker using two different weapons. She also had a blunt-force injury to her scalp.
Jasmine, age 8, died of asphyxiation, either by body compression or drowning. Dried blood found around her nose and mouth suggested she had been drowned. She was found in a bathtub. She also had small petechiae (tiny hemorrhages on the skin) all over her neck and face, suggesting body compression on the upper chest. Extensive injuries to her genitalia and anus, including severe tearing, stretching of the skin, hemorrhaging and bruising, suggested the use of extreme force by a blunt object.
The suspect in all these killings was Alfonso Ignacio Morales, a neighbor who regularly went over to the house to just “hang out,” especially with Mike. Morales was in his twenties. He had asked a sister of the victims out on a date (the sister was outside the house at the time of the killings). The sister had replied “maybe,” but confided to others that she did not want to go on a date with Morales, especially after she noticed him staring in at her from an outside window. The entire family knew about this staring incident and discussed it with Morales.
Investigators immediately identified him as a suspect, especially when they found bloody footprints in the house and Maritza’s blood on Morales’ boots and shoelaces. They also found a DNA match with sperm from Jasmine’s anus and vagina that matched Morales’ DNA. Investigators matched his palm print to a palm print on a mop located in the entryway to the victims’ house. They also found a box with bloody clothes and a six-inch Vaquero folding knife, as well as a five-inch United knife in a sheath and two bloody fingerless gloves.
Morales himself first denied knowing anything about the murders, then agreed he was in the house at the time of the murders, but that two other men performed the murders.
The jury convicted him on all counts and found true all the special circumstances of multiple murders and murder in the commission of a burglary (he stole a computer which was recovered at his home a few houses away). The jury also found true the special circumstance of murder by torture and murder in the commission of a lewd act upon a child under the age of 14. The judge sentenced him to death.
Morales then appealed the first-degree murder convictions, arguing it the evidence was insufficient to show he committed the murders with premeditation and deliberation.
The Second Appellate District, in People v. Alfonso Ignacio Morales (2020 DJDAR 8367) affirmed the convictions. It started from the point by reminding the reader that “premeditated” means “considered beforehand” and “deliberate” means “formed or arrived at or determined upon as a result of careful thought and weighing of considerations for and against the proposed course of conduct.” People v. Jurado (2006) 38 Cal.4th 72, 118.
In People v. Anderson (1968) 70 Cal.2d 15, 26, the court identified “three basic categories” of evidence that it has generally found sufficient to sustain a finding of premeditation and deliberation:
- Planning activity, or “facts about how and what defendant did prior to the actual killing which show that the defendant was engaged in activity directed toward, and explicable as intended to result in the killing";
- Motive, or “facts about the defendant’s prior relationship and /or conduct with the victim from which the jury could reasonably infer a “motive” to kill the victim"; and
- Manner of killing, or “facts about the nature of the killing from which the jury could infer that the manner of killing was so particular and exacting that the defendant must have intentionally killed according to a “preconceived design” to take his victim’s life in a particular way for a reason."
In the years following Anderson, the courts have emphasized that the guidelines are descriptive and neither normative nor exhaustive.
Here, the Second Appellate District pointed to evidence that Morales must have surreptitiously entered the house and killed Mike first, from behind, by slitting his throat. Witness testimony from a next-door neighbor seemed to corroborate this, as the witness testified to seeing a wooden stool outside the window where Mike was murdered, suggesting Morales entered the bedroom through the window. It was significant to Mr. Morales that Mike had no defensive wounds, suggesting Morales murdered him in one quick motion. Morales even suggested this was so, as in his odd “confession” to police, he stated that the other two men first killed Mike.
The appellate court also pointed to evidence of premeditation in the evidence of the bloody fingerless gloves found, as well as the hidden boxes with bloody knives found after the event in Morales’ backyard.
The horrific death of the eight-year old girl surely earned Morales no sympathy in appealing the death verdict, we believe.
The above case was later appealed to the California Supreme Court, which affirmed the convictions. The citation for the California Supreme Court ruling is People v. Alfonso Ignacio Morales (2020) 10 Cal. 5th 76, 266 Cal. Rptr. 3d 706, 470 P. 3d 605.