Does the doctrine of proximate causation apply to determine whether a victim has suffered bodily harm under the California Domestic Violence Act?

In People v. Monk (1961) 56 Cal.2d 288, 296, 14 Cal.Rptr. 633, 363 P.2d 865 the court held that the doctrine of proximate causation is applicable to determine whether the victim has suffered bodily harm within the terms of the statute. In that case the defendant was driving his kidnap victim in a car with a gun against her while threatening bodily harm and she injured herself when she threw herself out of the moving car [270 Cal.App.2d 49] to make her escape. The court held that his threatening conduct put her in fear and was the proximate cause of her injuries.