Can a sentence that conflicts with section 654 of the Criminal Code be challenged on appeal?

A sentence that conflicts with section 654 is unauthorized and ordinarily may be challenged on appeal regardless of whether it was preserved in the trial court. (People v. Hester (2000) 22 Cal.4th 290, 295.) However, where the appeal is from a judgment

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entered after defendant's guilty plea, compliance with section 1237.5 is required if the section 654 challenge impugns the validity of the plea. (People v. Cuevas (2008) 44 Cal.4th 374, 381 (Cuevas).) Under section 1237.5, "[a] defendant may not appeal 'from a judgment of conviction upon a plea of guilty or nolo contendere,' unless he has obtained a certificate of probable cause. ( 1237.5, subd. (b); [citation].) Exempt from this certificate requirement are postplea claims, including sentencing issues, that do not challenge the validity of the plea. (Cal. Rules of Court, rule 8.304(b)(4)(B); [citations].)" (Cuevas, at p. 379.) Therefore, "the critical inquiry is whether a challenge to the sentence is in substance a challenge to the validity of the plea, thus rendering the appeal subject to the requirements of section 1237.5. [Citation.]" (People v. Panizzon (1996) 13 Cal.4th 68, 76.)