What is the corpus delicti rule as it applies to robbery murder?

Prior to trial, the trial court conducted an Evidence Code section 402 hearing on the corpus delicti rule as it applied to "robbery murder." The trial court noted preliminarily that the case law, particularly People v. Jennings (1991) 53 Cal.3d 334, appeared to support the People's argument that the elements of the predicate crime of robbery did not have to be proved by independent evidence in order to arrive at a charge of felony murder. The trial court nevertheless asked the prosecutor to delineate what inferences could be drawn from the independent evidence.