What is the test for using the term "disfigure" in medical malpractice cases?

The wide variety of serious injuries set forth by the court in Santana amply illustrate the ability of jurors to distinguish between the grave nature of the disfigurement proscribed by sections 203 and 205 and mere blemishes or minor but visible scars that would not support a conviction. Thus, contrary to defendants' contention, there was no basis upon which the trial court was required to sua sponte offer an instruction clarifying such a commonly understood term. (See People v. Estrada (1995) 11 Cal.4th 568, 574.)

The common understanding of the term "disfigure" also largely disposes of

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