Is possession of recently stolen property sufficient to convict a defendant of a theft-related crime?

Appellant was convicted of the unlawful driving or taking of a vehicle ( 10851, subd. (a))⁶ but was acquitted of receiving a stolen motor vehicle (Pen. Code 496d, subd. (a)). CALCRIM No. 376 instructs a jury that possession of recently stolen property is insufficient alone to convict a defendant of a theft-related crime.⁷ The parties agree the trial court had no sua sponte duty to give the instruction. (See People v. Najera (2008) 43 Cal.4th 1132, 1136 [no "sua sponte duty to instruct on the limited significance of possession of recently stolen property in theft-related prosecutions"].) However, appellant contends his trial counsel's failure to request the instruction was ineffective assistance of counsel.