What is the test for admitting hearsay evidence in a criminal case?

Evidence Code section 1230 provides, "Evidence of a statement by a declarant having sufficient knowledge of the subject is not made inadmissible by the hearsay rule if the declarant is unavailable as a witness and the statement, when made, was so far contrary to the declarant's pecuniary or propriety interest, or so far subjected him to the risk of civil or criminal liability . . . that a reasonable man in his position would not have made the statement unless he believed it to be true." "'The proponent of such [hearsay] evidence must show that the declarant is unavailable, that the declaration was against the declarant's penal interest when made and that the declaration was sufficiently reliable to warrant admission despite its hearsay character.'" (People v. Grimes (2016) 1 Cal.5th 698, 741 (Grimes); accord, People v. Duarte (2000) 24 Cal.4th 603, 610-612.)

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