Can a recording of a conversation be used as evidence in a criminal trial?

People v. Patton (1976) 63 Cal.App.3d 211, 220, 133 Cal.Rptr. 533 [holding that a "tape recording is not barred by the best evidence rule merely because a witness to the conversation is available"]; People v. Kulwin (1951) 102 Cal.App.2d 104, 109, 226 P.2d 672 [recognizing that "recordings might be more reliable and satisfactory evidence under circumstances than testimony from memory"].) As such, our state Constitution requires that the recording "shall not be excluded" in defendants criminal trial. ( Art. I, 28(f)(2).)