Can a conspiracy be used to prove criminal liability for acts of the coconspirator?

"It is long and firmly established that an uncharged conspiracy may properly be used to prove criminal liability for acts of a coconspirator. [Citations.] 'Failure to charge conspiracy as a separate offense does not preclude the People from proving that those substantive offenses which are charged were committed in furtherance of a criminal conspiracy [citation]; nor, it follows, does it preclude the giving of jury instructions based on a conspiracy theory [citations].' " (People v. Belmontes (1988) 45 Cal.3d 744, 788-789 (Belmontes), disapproved on other grounds in People v. Doolin (2009) 45 Cal.4th 390, 421, fn. 22.)