In People v. Candelaria (1956) 139 Cal. App. 2d 432, the defendant was subject to state and federal prosecutions for the same act of robbing a bank teller on December 11, 1956. He had been previously convicted in federal court of the robbery and raised section 656 as a defense to the state charge. The court determined that application of section 656 depended upon "whether the previous federal conviction was 'founded upon the act' in respect to which the defendant was thereafter tried in the state court." ( Candelaria, supra, 139 Cal. App. 2d at p. 440.) It concluded in the affirmative: "The only additional element involved in the federal prosecution was that the money belonged to a national bank whose deposits were federally insured. That additional element, regarding the status of title to or insurance on the money, pertained to the matter of jurisdiction of the federal court, and it did not pertain to any activity on the part of defendant in committing the robbery. The physical act or conduct of defendant in taking the money was the same whether the robbery be considered as a federal offense or a state offense. All the acts constituting the state offense were included in the federal offense and were necessary to constitute the federal offense." (Ibid.) The court reversed the state judgment of conviction and remanded to the trial court "to determine, as a matter of law, that the previous federal conviction is a sufficient defense." ( Id. at p. 441.)