Can a jury be instructed on the natural and probable consequences or felony murder theory of liability?

⁵ For example, if the jury was not instructed on a natural and probable consequences or felony murder theory of liability, the petitioner could not demonstrate eligibility as a matter of law because relief is restricted to persons convicted under one of those two theories. (See People v. Lewis (2020) 43 Cal.App.5th 1128, 11381139, 257 Cal.Rptr.3d 265, review granted Mar. 18, 2020, S260598 (Lewis ) [appellate court opinion holding that jury convicted defendant of murder as a direct aider and abettor barred defendant from relief as a matter of law].)