Angel Sanabria, a 26-year-old resident of San Diego, California, tragically lost his life on April 1, 2017. Angel was fatally shot in an alley off the 3200 block of 44th Street, near Monroe Clark Middle School in the City Heights neighborhood. The incident occurred when two men opened fire on Angel and another individual, who survived the attack. Angel, who was expecting a child, was remembered by his community and loved ones during a vigil held at New Harvest Christian Fellowship Church.
The community gathered to promote peace and support Angel's grieving family, emphasizing the impact of violence on their neighborhood.
The investigation into Angel Sanabria's death revealed that the shooting was not gang-related, and the victims did not know their attackers. The suspects, identified as Luis Dominguez and Abraham Torres, were part of a neighborhood "tagging crew" that had conflicts with the Eastside San Diego gang, of which Angel and the other victims were members or associates. During the trial, both defendants admitted to being the shooters but claimed they acted in panic and fear when Angel confronted them and appeared to reach for a weapon. The court instructed the jury on self-defense and voluntary manslaughter based on imperfect self-defense but refused to instruct on voluntary manslaughter based on heat-of-passion due to insufficient evidence of provocation.
The jury ultimately convicted Luis Dominguez and Abraham Torres of second-degree murder for Angel Sanabria's death and attempted murder for wounding Joseph Luna. They were acquitted of first-degree murder and other charges related to the incident. Dominguez was sentenced to 16 years, plus 65 years to life, while Torres received 17 years, plus 65 years to life. On appeal, the defendants argued that the trial court erred in refusing to instruct on voluntary manslaughter based on heat-of-passion and that the "kill zone" instruction for attempted murder was erroneous. The Court of Appeal agreed, reversing the judgments and remanding the cases for a new trial on the reversed convictions.
