In Patrick v. Maryland Casualty Co. (1990) 217 Cal. App. 3d 1566, in describing the standard of review on appeal, the court said: "We review the record for substantial evidence of circumstances warranting the imposition of punitive damages. We reject appellant's argument that a more stringent standard than the normal substantial evidence rule should apply due to the 1987 amendments to Civil Code section 3294, subdivision (a) which required that the trier of fact find 'clear and convincing evidence' of malice, fraud, or oppression. Despite the difference in the standard for the determination of this issue by the trier of fact, it has been held that in such circumstances the substantial evidence test applied by the reviewing court is not altered. (Crail v. Blakely (1973) 8 Cal.3d 744, 750 'That standard of clear and convincing evidence was adopted, however, for the edification and guidance of the trial court, and was not intended as a standard for appellate review. . . . "If there is substantial evidence to support its conclusion, the determination is not open to review on appeal." '" (Patrick, supra, 217 Cal. App. 3d at p. 1576.)