What is the test for determining whether there is an element of force required for robbery?

Robbery is "the felonious taking of personal property in the possession of another, from his person or immediate presence, and against his will, accomplished by means of force or fear." (Pen. Code, 211.) The amount of force required for robbery is something more " 'than just that quantum of force which is necessary to accomplish the mere seizing of the property.' " (People v. Burns (2009) 172 Cal.App.4th 1251, 1259.) That is, the force required is such force as is actually sufficient to overcome the victim's resistance. (Ibid.) Furthermore, the element of fear is satisfied when " 'there is sufficient fear to cause the victim to comply with the unlawful demand for [her] property.' " (People v. Morehead (2011) 191 Cal.App.4th 765, 774 (Morehead).) The jury can infer fear from the circumstances, and it is not necessary for the victim to testify that he or she was afraid. (Id. at p. 775.) Also, the victim's fear need not be the result of the use of a weapon or of an express threat of any kind. (Ibid.) If the victim was intimidated, the jury may equate that with fear. (Ibid.)