What is the test for provocation in the context of an intentional, unlawful homicide?

The instruction correctly states that provocation is an essential element of voluntary manslaughter. "An intentional, unlawful homicide is 'upon a sudden quarrel or heat of passion' ( 192(a)), and is thus voluntary manslaughter (ibid.), if the killer's reason was actually obscured as the result of a strong passion aroused by a 'provocation' sufficient to cause an ' "ordinary [person] of average disposition . . . to act rashly or without due and reflection, and from this passion rather than from judgment." ' " (People v. Breverman (1998) 19 Cal.4th 142, 163.) Defendant misconstrues provocation as "victim-caused provocation" and, from that misconstruction, reasons that provocation is not required for a killing upon a sudden quarrel. In fact, legal provocation within the meaning of voluntary manslaughter is broader than victim-generated provocation and encompasses acts or circumstances that would " 'render an ordinary person of average disposition "liable to act rashly or without due deliberation and reflection, and from this passion rather than from judgment." ' " (People v. Duff (2014) 58 Cal.4th 527, 562.) As CALCRIM No. 570 correctly states, "no specific type of provocation is required." "Heat

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