What is the test for "Any substantial evidence" in a criminal case?

"It is abhorrent to any sense of justice that persons be convicted of crimes they did not commit. Perfection of course is not attainable in this world, but that furnishes no reason why the law should not, within reason, continually strive to prevent such miscarriages of justice. Yet nothing would seem better calculated to perpetuate such injustice, than an 'Any substantial evidence' rule which limits the evidence which may be considered in determining whether, as a matter of law, there is sufficient evidence to convict." (People v. Blum, supra, 35 Cal.App.3d 515 at p. 529, 110 Cal.Rptr. at p. 842.)

In Jackson v. Virginia (1979) --- U.S. ----, 99 S.Ct. 2781, 60 L.Ed.2d ---, the United States Supreme Court recently held in a juvenile proceeding that a federal habeas corpus court must consider not whether there was Any evidence to support a state court conviction, but whether there was sufficient evidence to justify a rational trier of fact to find guilt beyond a reasonable doubt, citing In re Winship, supra. The high court held that In re Winship presupposes as an essential of the due process guaranteed by the Fourth Amendment that no person shall be made to suffer a criminal conviction except upon sufficient proof defined as evidence necessary to convince a trier of fact beyond a reasonable doubt of the existence of Every element of the offense. This "subjective state of near certitude of the guilt of the accused . . . symbolizes the significance that our society attaches to the criminal sanction and thus to liberty itself." (Jackson v. Virginia, supra, 99 S.Ct. at p. 2787.) The critical inquiry on review of the sufficiency of the evidence to support a [95 Cal.App.3d 71] criminal conviction must be not simply to determine whether the jury was properly instructed on reasonable doubt (or that a trial or juvenile judge understood the heavy burden of proof) but to determine whether the record evidence could reasonably support a finding of guilt beyond a reasonable doubt. The relevant question thus is whether, after viewing the evidence in the light most favorable to the prosecution, any Rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.

The conclusion is inescapable: under the authority of Jackson v. Virginia, supra, the Any substantial evidence rule is no longer the law in California in the review of criminal convictions since it does not comport with due process. The appellate court must examine the entire record in deciding whether there is substantial evidence to support the conviction. This being so, the habit evidence in the present case must be viewed in light of the victim's inability to recall shortly after leaving the vehicle whether he had locked the doors, the absence of signs of forced entry into the vehicle, and the absence of any burglary tools such as a wire clothes hanger in appellant's possession. When all of these facts are considered, it is readily apparent that no reasonable trier of fact could have found beyond "all reasonable doubt" that the doors were locked when appellant entered the vehicle.

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