In People v. Francisco (1994) 22 Cal.App.4th 1180, the appellate court rejected a contention that "allowing the theory of aiding and abetting of an assault with a firearm to be the basis for a finding of murder violates the Ireland principles." (Francisco, at p. 1189.) The appellate court observed that in People v. Ireland (1969) 70 Cal.2d 522, "the Supreme Court held that a felony-murder theory cannot be based on a felony which is an integral part of the homicide because such a theory would preclude the jury from considering malice aforethought in all cases wherein the homicide has been committed as a result of a felonious assault. However, aiding and abetting is one means under which derivative liability for the commission of a criminal offense is imposed. It is not a separate criminal offense. As an aider and abettor, it is the intention to further the acts of another which creates criminal liability. The '"natural and probable consequences"' standard under CALJIC No. 3.02 which allows a finder of fact to render a verdict on derivative aider and abettor liability, presents an 'all-encompassing standard for proper lay application of law to relevant evidence on the issue of legal causation of a criminal act.' If the principal's criminal act which is charged to the aider and abettor is a reasonably foreseeable consequence to any criminal act of that principal, and is knowingly aided and abetted, then the aider and abettor of such criminal act is derivatively liable for the act charged. For this reason, the logical and legal impediments to criminal liability as found in Ireland are not applicable and do not have persuasive value with respect to limiting an aider and abettor's liability." (Id. at p. 1190.) In Francisco, supra, 22 Cal.App.4th 1180, in rejecting a contention that CALJIC No. 3.02 meant a defendant "could be found guilty without a finding that he shared the perpetrator's intent to kill," the appellate court noted "this is not the test for aider and abettor liability. Such liability is a question of legal causation which is independent of any intent that the result in question occurred. Thus, the ultimate factual question is whether the perpetrator's criminal act, upon which the aider and abettor's derivative criminal liability is based, was '"reasonably foreseeable"' or the probable and natural consequence of a criminal act encouraged or facilitated by the aider and abettor." (Francisco, at p. 1190.)