Can a defendant plead guilty to voluntary manslaughter after the statute of limitations has expired?

We find no clear rule for cases where the offense was committed outside the nominal statutory period, the accusatory pleading contains allegations in avoidance of the statute, and the defendant does not secure an express ruling from the trial court concerning the timeliness of the action. In Cowan v. Superior Court (1996) 14 Cal.4th 367, the question was whether a defendant charged with capital murderan offense for which there is no statute of limitationscould be convicted of voluntary manslaughter, on a plea of guilty, after the statutory period for prosecution on that charge had expired. The court recognized that if the statute were truly "jurisdictional" in the sense that it

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