Does the corpus delicti rule preclude conviction based solely on a defendant's out-of-court statement?

The corpus delicti rule precludes conviction based solely on a defendant's out-of-court statements. (People v. Ray (1996) 13 Cal.4th 313, 341.) "In every criminal trial, the prosecution must prove the corpus delicti, or the body of the crime itselfi.e., the fact of injury, loss, or harm, and the existence of a criminal agency as its cause. In

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California, it has traditionally been held, the prosecution cannot satisfy the burden by relying exclusively upon the extrajudicial statements, confessions, or admissions of the defendant. [Citations.]" (People v. Alvarez (2002) 27 Cal.4th 1161, 1168-1169.) "This rule is intended to ensure that one will not be falsely convicted, by his or her untested words alone, of a crime that never happened." (Ibid.)

The California courts have held that the defendant may not be held to answer absent independent evidence of the corpus delicti at the preliminary examination. At trial, a defendant's extrajudicial statements are inadmissible over a corpus delicti objection if no independent evidence of the crime exists. (People v. Alvarez, supra, 27 Cal.4th at pp. 1169-1170.)