When a fraud claim is based upon misrepresentation or nondisclosure by a fiduciary, is the reliance element relaxed?

When a fraud claim is based upon a misrepresentation or nondisclosure by a fiduciary, "the reliance element is relaxed . . . to the extent we may presume reasonable reliance . . . absent direct evidence of a lack of reliance." (Estate of Gump (1991) 1 Cal.App.4th 582, 601; Edmunds v. Valley Circle Estates (1993) 16 Cal.App.4th 1290, 1302 ["a representation in the context of a trust or fiduciary relationship creates a rebuttable presumption of reasonable reliance subject to being overcome by substantial evidence to the contrary"].) "This rebuttable presumption implements the long recognized public policy of imposing fiduciary duties upon partners in their relationship to one another." (Edmunds, at p. 708.)