The New Mexico Supreme Court has upheld the first-degree murder conviction of Ruben Benavidez, who was 17 years old when he fatally shot his mother’s boyfriend, Cedric Guzman, in Albuquerque in 2022.
Justice Julie J. Vargas wrote the unanimous opinion. The Court found that there was enough evidence to support the jury’s conclusion that Benavidez acted with deliberate intent. Benavidez had argued that he did not kill Guzman deliberately but was provoked.
The justices overturned one of Benavidez’s two convictions for evidence tampering, citing constitutional protections against double jeopardy. They determined that both pieces of evidence—the murder weapon and a hoodie—were hidden during a single incident.
According to court records, Benavidez and his younger sister had not seen their mother for a week and asked their father for help locating her. They found her car at Guzman’s apartment. After an exchange at the door between Guzman and the family, Benavidez kicked the door twice. When Guzman opened it and approached him, words were exchanged before Guzman spat at Benavidez. Benavidez then fired two shots from inside his hoodie pocket, hitting Guzman in the arm and abdomen. Guzman died from his injuries. The incident was captured by a security camera.
Afterward, Benavidez hid the handgun in a ceiling vent and placed his hoodie under a couch wrapped in a trash bag at his older sister’s apartment. Police later recovered these items; shell casings found matched the handgun.
The Court noted: “Defendant arranged to be taken to Victim’s apartment on the morning of the killing, and after confirming Victim’s presence in that apartment, approached Victim in a highly confrontational manner. He violently kicked on the front door of the apartment, checked the gun in his pocket, and then goaded Victim by trading insults and telling Victim to ‘do something.’ The jury could reasonably infer a deliberate intent to kill from Defendant’s engagement with and immediate aggression towards Victim,” according to its written opinion.
Benavidez also challenged aspects of his trial including jury instructions about provocation and alleged prosecutorial misconduct during closing arguments; both arguments were rejected by the Court.
He received a 30-year prison sentence with eight years suspended. Because he was 17 at the time—a status defined as serious youthful offender under state law—the trial court was not required to impose life imprisonment.
On appeal, Benavidez contested having five years of parole imposed as part of his sentence instead of two years; he argued that only those sentenced to life imprisonment should receive five years’ parole under state law. However, this case marked the first time New Mexico’s highest court addressed what parole term applies when someone convicted as a serious youthful offender for first-degree murder receives less than life imprisonment.
The justices explained: “The district court’s mitigation of Defendant’s sentence does not transform the legislative classification of his capital crime.” They concluded: “the Legislature intended that a serious youthful offender convicted of first-degree murder serve a five-year period of parole, regardless of any mitigation in the offender’s prison sentence.”
For more details or to read State v. Benavidez (No. S-1-SC-40452), visit https://nmonesource.com/nmos/nmsc/en/item/537870/index.do
