How have courts treated sanctions awarded under Code of Civil Procedure section 128.5?

In Bank v. Manos (1991) 232 Cal.App.3d 123, 128-129, 283 Cal.Rptr. 318, the appellate court observed that "an award under Code of Civil Procedure section 128.5 is more like a money judgment compensating a party for harmful conduct than it is like an award of fees as part of the costs of the lawsuit. [p] ... Code of Civil Procedure section 128.5 does not refer to costs but instead imposes 'reasonable expenses' as an element of sanctions.... [p] An award of sanctions is more like a money judgment than it is like costs because of the unusual nature of such an award...." In accordance therewith, the court held that "an award of sanctions under Code of Civil Procedure section 128.5 does not represent costs but is essentially a judgment for money damages which must be bonded." (Id. at pp. 128-129, 283 Cal.Rptr. 318.)