When there are multiple concurrent causes of death in a motor vehicle accident, what is the test for determining proximate causation?

"When there are multiple concurrent causes of death, the jury need not decide whether the defendant's conduct was the primary cause of death, but need only decide whether the defendant's conduct was a substantial factor in causing the death. [Citations.] [] Further, proximate causation requires that the death was a reasonably foreseeable, natural and probable consequence of the defendant's act, rather than a remote consequence that is so insignificant or theoretical that it cannot properly be regarded as a substantial factor in bringing about the death." (People v. Butler (2010)

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187 Cal.App.4th 998, 1009-1010.) But-for causation is not required and as " 'long as the jury finds that without the criminal act the death would not have occurred when it did, it need not determine which of the concurrent causes was the principal or primary cause of death.' [Citation.]" (People v. Jennings (2010) 50 Cal.4th 616, 643-644; see People v. Catlin (2001) 26 Cal.4th 81, 155.)²