What constitutes "great bodily injury" in a motor vehicle accident?

For purposes of this section, great bodily injury "means a significant or substantial physical injury." (People v. Escobar (1992) 3 Cal.44th 740, 749-750; 12022.7, subd. (f).) The fact that the injury is significant or substantial "is commonly established by evidence of the severity of the victim's physical injury, the resulting pain, or the medical care required to treat or repair the injury." (People v. Cross (2008) 45 Cal.4th 58, 66.) The determination of "whether a victim has suffered physical harm amounting to great bodily injury is not a question of law for the court but a factual inquiry to be resolved by the jury." (Id. at p. 64.)