What is the test for determining whether a defendant inflicted great bodily injury on an accomplice who did not personally inflict the injury?

sufficiency of the evidence supporting the jury's great bodily injury finding, "we view the evidence in the light most favorable to the judgment to determine whether it discloses substantial evidence, i.e., evidence that is reasonable, credible, and of solid value, such that a reasonable trier of fact could find the essential elements of the charged crime or allegation proven beyond a reasonable doubt [Citations.]" (People v. Elder (2014) 227 Cal.App.4th 411, 417.) "[W]e review the evidence in the light most favorable to the prosecution and presume in support of the judgment the existence of every fact the jury could reasonably have deduced from the evidence. [Citation.]" (People v. Zamudio (2008) 43 Cal.4th 327, 357.)

Appellant relies on People v. Cole (1982) 31 Cal.3d 568, to support his theory that he did not personally inflict great bodily injury on Martinez. That case, however, dealt with whether an accomplice who "directed the attack and blocked the victim's escape, [but] did not actually strike the victim," was subject to the section 12022.7, subdivision (a) enhancement. (Id. at p. 572.) When the court stated that the "enhancement applies only to a person who himself inflicts the injury" (ibid.), it was referring to the defendant's status as an accomplice who did not actually strike the victim. Cole has no direct application outside of the context of accomplice liability, "though it does provide a definition of '"personally,"' for which the court adopts the dictionary definition of '"done in person without the intervention of another; direct from one person to another."' [Citation.]" (People v. Warwick (2010) 182 Cal.App.4th 788, 793.)