Can a defendant enter a plea to second degree murder to allow trial court to determine degree?

Sanchez v. Superior Court (2002) 102 Cal.App.4th 1266, 12671268, 126 Cal.Rptr.2d 200 [defendant charged with special circumstance could not enter plea to unspecified degree of murder to allow trial court to determine degree].) But rules governing the fixing of a crime's degree upon entry of a plea do not affect the issue whether the charging document permits the People to proceed upon a particular theory. Particularly where, as here, a defendant ultimately enters a plea to second degree murder, the allegation of a special circumstance requiring an intent to kill does not preclude prosecution based on the natural and probable consequences doctrine.