What is the error that resulted from the instruction to the jury that it should consider each of the six multiple-murder special-circumstance allegations as an aggravating factor in the penalty phase?

The error here resulted from the instruction to the jury that it should consider each of the special circumstances it had found true as an aggravating factor. Because [751 P.2d 441] the jury had found six multiple-murder special-circumstance allegations true, when there should have been only a single special circumstance, the instruction could, theoretically, have led the jury to base its assessment of defendant's culpability on the sheer number of special circumstances rather than on the underlying conduct. After consideration of the entire record in this case, we conclude that the possibility that the jury may have based its penalty decision, even in part, on the sheer number of special circumstances it had found true, rather than on defendant's conduct, is far too remote and speculative to suggest that the jury would have reached a different verdict had it considered the murders as a single special circumstance. Review of the record here reveals no reference by the prosecutor to the multiple-murder special circumstances during his penalty-phase argument. The jurors were well aware of the actual number of victims and their consideration of multiple murder as an aggravating factor which the state identifies as being particularly relevant to the penalty decision was permissible. Only were we to assume that the jury for some reason believed that the murders were more heinous because they generated six multiple-murder special-circumstance allegations through the cross-charging would the failure to limit the multiple-murder factor to a single special circumstance result in prejudice. Nothing in the manner in which this case was tried, or in the penalty phase argument and instructions, affords a basis on which to speculate that the jury may have been influenced by the number of multiple-murder special circumstances. We conclude, as we did in People v. Allen, supra, 42 Cal.3d 1222, 1281-1283, 232 Cal.Rptr. 849, 729 P.2d 115, that the error was harmless.