In what circumstances have courts overturned sentences for forgery and grand theft?

In People v. Rosenberg (1963) 212 A.C.A. 791, 28 Cal.Rptr. 214, the defendant pleaded guilty to grand theft and also to the forgery of a fictitious name, and was sentenced upon both charges. On appeal, the court held that the defendant was motivated by but one objective and that the forgery was but an incident to and the means of perpetrating the theft. The court ordered the sentence on the grand theft charge set aside, as the forgery was subject to the greater punishment.