How is the substantial evidence test applied in criminal cases?

The role of the appellate court in applying the substantial evidence test is well established. It is to determine whether there is substantial evidence to support the conclusions of the trier of fact and not whether guilt is established beyond a reasonable doubt. (People v. Redmond (1969) 71 Cal.2d 745, 755, 79 Cal.Rptr. 529, 457 P.2d 321.) To this end, the appellate court must view the evidence in the light most favorable to respondent and, before the judgment can be reversed, it must clearly appear that upon no reasonable hypothesis whatever is there substantial evidence to support it.

In People v. Groom (1964) 60 Cal.2d 694, 696--697, 36 Cal.Rptr. 327, 329, 388 P.2d 359, 361, the court states: 'Unlawful possession of narcotics is established by proof (1) that the accused exercised dominion and control over the contraband, (2) that he had knowledge of its presence, and (3) that the accused had knowledge that the material was a narcotic. (Citation.) The foregoing elements may be established by circumstantial evidence and any reasonable inferences drawn from such evidence. (Citation.) And finally when the sufficiency of the evidence is challenged an appellate court must affirm if the record contains substantial evidence of all elements of the crime. (Citation.)'

As we noted in People v. Fusaro (1971) 18 Cal.App.3d 877, 891, 96 Cal.Rptr. 368, 377, '(e)xclusive possession of the premises where the drug is found is not required, nor is physical possession of the drug.'