Can a defendant challenge the sufficiency of evidence to support a default judgment?

Defendants are entitled to challenge the sufficiency of the evidence to support the default judgment. (Kim v. Westmoore Partners, Inc. (2011) 201 Cal.App.4th 267, 288.) " '[T]he general rule that the sufficiency of the evidence tendered in a default proceeding cannot be reviewed on an appeal from a default judgment . . . is true as to matters for

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which no proof is required by virtue of the admission by default of the allegations of the complaint. [Citation.] However, as to damages which, despite default, require proof[,] the general rule does not apply.' " (Scognamillo v. Herrick (2003) 106 Cal.App.4th 1139, 1150.) Thus, an appellate court will reverse damages awarded on a default judgment not only when the award is so excessive that it "shocks the conscience" and is the result of "passion [or] prejudice," but also when "the damages awarded are unsupported by sufficient evidence." (Ibid.)