What are the implications of the People v. Superior Court argument that the evidence of provocation or self-defense is insufficient?

'The People also argue that in People v. James (1950) 99 Cal.App.2d 476, 222 P.2d 117, and Jackson v. Superior Court, supra, 62 Cal.2d 521, 42 Cal.Rptr. 838, 399 P.2d 374, the evidence of provocation or self-defense was insufficient. These cases do not aid the People. [275 Cal.App.2d 601] Each case must turn on its own facts, and the factual situation in the case before us is dissimilar to the factual situations in the cases cited by the People.' (265 A.C.A. supra, at p. 114, 71 Cal.Rptr. at p. 105.)