What is the test for admitting or denying false statements by a defendant in a criminal case?

We begin with the established California precedent. In People v. Cole (1903) 141 Cal. 88, 74 P. 547, the defendant, a shipping clerk and salesman employed by a furniture store, was accused of improperly selling some of the store's carpets and keeping the proceeds of the sale. When charged with the crime, he denied delivering the carpets in question to anyone, and denied even knowing the person who had purchased the goods. The court admitted evidence of these statements at trial, and on appeal defendant asserted the statements should have been excluded. The Cole court rejected the claim, explaining: "This denial of defendant we think was competent and proper evidence to go to the jury for what it was worth. If the jury believed that defendant delivered the property, disclosed by the testimony of some three witnesses, then the fact that defendant denied the delivery was a circumstance tending to show that the delivery was not made innocently in his capacity as a salesman, but with intent to steal the property. If he had delivered the property innocently, the most natural thing for [44 Cal.3d 497] him to have done was to tell the truth about it. If he intended to steal it, the most natural thing for him to do when questioned about it was to lie concerning it. Deception, falsehood, and fabrications as to the facts of the case are treated as tending to show consciousness of guilt, and are admissible on the same theory as flight and concealment of the person when charged with crime." (Id., at pp. 89-90, 74 P. 547, italics added.) Thus, even though the falsity of the defendant's prior statement was not proved by its inconsistency with the defendant's subsequent testimony but by the testimony of other witnesses, the statement was found admissible.