What is the prosecution's burden to prove the elements of a sentence enhancement under the California Robbery Act?

the trier of fact may draw reasonable inferences from the record presented. Absent rebuttal evidence, the trier of fact may presume that an official government document, prepared contemporaneously as part of the judgment record and describing the prior conviction, is truthful and accurate. Unless rebutted, such a document, standing alone, is sufficient evidence of the facts it recites about the nature and circumstances of the prior conviction. [Citations.]" (People v. Miles (2008) 43 Cal.4th 1074, 1082-1083.) It is the prosecution's burden to prove the elements of the sentence enhancement beyond a reasonable doubt, and "[o]n review, we examine the record in the light most favorable to the judgment to ascertain whether it is supported by substantial evidence." (Id. at p. 1083.)

In California, a robbery is defined as "the felonious taking of personal property in the possession of another, from his person or immediate presence, and against his will, accomplished by means of force or fear." ( 211.) The statute has been interpreted as requiring the specific intent to permanently deprive the victim of the property, although "permanently" is not an inflexible concept, and may include an intent to keep the property for an unreasonable period of time or use it in such a way as to deprive it of most of its value. (People v. Avery (2002) 27 Cal.4th 49, 54-56.)⁴

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