How has the jury been instructed on flight after crime as evidence of guilt?

4. Instruction on Flight as Evidence of Guilt. The jury was instructed under CALJIC No. 2.52 that flight after crime may be considered as evidence of guilt. Relying on People v. Parrish (1986) 185 Cal.App.3d 942, 946-948, 230 Cal.Rptr. 118, and a line of cases running back to People v. Anjell (1979) 100 Cal.App.3d 189, 199-202, 160 Cal.Rptr. 669, defendant asserts that the instruction should not have been given because he denied participation in the crimes and proffered an alibi defense.

Defendant's reliance on these cases is misplaced, and the giving of CALJIC No. 2.52 was not error. (See also People v. Cowger (1988) 202 Cal.App.3d 1066, 1073-1076, 249 Cal.Rptr. 240.) The instruction was not [49 Cal.3d 314] directed at an immediate flight after crime, but at defendant's later escape from the county jail. ¹² His escape from jail after being arrested and charged with the crimes was properly admissible as indicating consciousness of guilt. (People v. Holt (1984) 37 Cal.3d 436, 455, 208 Cal.Rptr. 547, 690 P.2d 1207.) Although it would have been preferable had the trial court deleted any reference in the instruction to flight "immediately after the commission of a crime" and instructed the jury only as to flight after defendant was "accused of a crime," the prosecutor's argument made clear to the jury that only defendant's escape from jail was implicated by this instruction.

5. Informant Witness Instruction. Defendant next challenges the failure of the trial court sua sponte to instruct the jury that the testimony of informants, like that of accomplices, should be viewed with care and caution, and with distrust. Although conceding that, under People v. Alcala (1984) 36 Cal.3d 604, 205 Cal.Rptr. 775, 685 P.2d 1126, the testimony of informants is not subject to the same corroboration requirements as that of accomplices, defendant contends that the giving of cautionary instructions as to accomplice testimony

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