What is the test for proving constructive possession of property in a robbery case?

We apply a substantial evidence standard of review to assess the sufficiency of the evidence. We review the entire record in the light most favorable to the judgment to determine whether it contains substantial evidence-that is, evidence that is reasonable, credible, and of solid value-from which a reasonable trier of fact could find the defendant guilty beyond a reasonable doubt. (People v. Steele (2002) 27 Cal.4th 1230, 1249.) We

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presume in support of the judgment the existence of every fact that could reasonably be deduced from the evidence. (People v. Kraft (2000) 23 Cal.4th 978, 1053.) We ask whether, after viewing the evidence in the light most favorable to the judgment, any rational trier of fact could have found the allegations to be true beyond a reasonable doubt. (Jackson v. Virginia (1979) 443 U.S. 307, 319.)

Robbery is 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.) To prove robbery, the prosecution must establish the defendant took property from the victim "by means of force or fear with the specific intent to permanently deprive him of that property." (People v. Young (2005) 34 Cal.4th 1149, 1176-1177.) However, "[a] robbery cannot be committed against a person who is not in possession of the property taken or retained." (People v. McKinnon (2011) 52 Cal.4th 610, 687.) Yet, the victim does not have to be the owner of the property (People v. Estes (1983) 147 Cal.App.3d 23, 26) and physical possession is not required to establish the element of possession (McKinnon, supra, at p. 687). Indeed, possession may be actual or constructive. (Ibid.; People v. Nguyen (2000) 24 Cal.4th 756, 764.)

A person who has the right to control property has constructive possession of it. (People v. Scott (2009) 45 Cal.4th 743, 750.) "For constructive possession, courts have required that the alleged victim had authority or responsibility to protect the stolen property on behalf of the owner." (Ibid.) Constructive possession is often recognized where the robbery involves business property taken from the business in the presence of

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