What constitutes "great bodily injury" under section 12022.7 of the California Criminal Code?

Section 12022.7 provides in pertinent part: "(a) Any person who personally inflicts great bodily injury on any person other than an accomplice in the commission of a felony or attempted felony shall be punished by an additional and consecutive term of imprisonment in the state prison for three years. [] . . . [] (f) As used in this section, 'great bodily injury' means a significant or substantial physical injury." There is no question that pregnancy resulting from unlawful sexual intercourse constitutes great bodily injury: "A pregnancy resulting from a rape (and, in this case, a resulting abortion) are not injuries necessarily incidental to an act of rape. The bodily injury involved in a pregnancy . . . is significant and substantial. Pregnancy cannot be termed a trivial, insignificant matter. It amounts to significant and substantial bodily injury or damage. It involves more than the psychological and emotional distress necessarily incident to a rape . . . ." (People v. Sargent (1978) 86 Cal.App.3d 148, 151.) Whether a victim's pregnancy constituted great bodily injury is a question of fact for the jury to decide. (People v. Meneses (2011) 193 Cal.App.4th 1087, 1091.)