Does the common law felony-murder rule apply to murder?

Later in 1965, in People v. Gilbert, 63 Cal.2d 690, 47 Cal.Rptr. 909, 408 P.2d 365, the court applied the rules enunciated in Washington, supra, to reverse the murder conviction of two defendants for the death of their [46 Cal.App.3d 796] accomplice during an attempted escape from the scene of the crime. The court, summarizing its earlier holding in Washington, stated 'that since the purpose of the common-law felony-murder rule is to deter felons from killing negligently or accidentally by holding them strictly responsible for killings they commit, malice aforethought cannot be imputed under that rule unless a felon commits the killing. We recognized, however, that entirely apart from the felony-murder rule, malice may be established when a defendant initiates a gun battle, and that under such circumstances he may be convicted of murder for a killing committed by another.' (63 Cal.2d at 704, 47 Cal.Rptr. at 917, 408 P.2d at 373.) ²