What is the test for determining whether a lower court's application of the law to the facts should be reviewed independently or deferentially?

We will uphold a trial court's determination on factual issues if supported by substantial evidence and review its legal determinations independently. (See People v. Cromer (2001) 24 Cal.4th 889, 894, 103 Cal.Rptr.2d 23, 15 P.3d 243.) Although our prior cases do not clearly establish whether the lower court's application of the law to the facts should be reviewed independently or deferentially on the issue before us (see, e.g., People v. Morante, supra, 20 Cal.4th 403, 84 Cal. Rptr.2d 665, 975 P.2d 1071; People v. Anderson, supra, 55 Cal.2d at p. 655, 12 Cal.Rptr. 500, 361 P.2d 32), we would uphold the trial court's decision in this case under either standard.