In People v. Jones (1998) 17 Cal.4th 279, the victim had been shot in the head and killed. Semen was found in her vagina, in her rectum, and on her external genitalia; it was not found in her mouth, but there was expert testimony that it could have been eliminated by "the mouth's natural rinsing processes." (Id. at pp. 291, 302.) The defendant admitted aiding and abetting his accomplice's forcible rape and forcible oral copulation of the victim. (Id. at pp. 292, 300.) The trial court ruled that sufficient evidence of forcible oral copulation had been presented at the preliminary hearing. (Id. at pp. 300-301.) The defendant was then convicted of (among other things) murder with rape and oral copulation special circumstances, forcible rape in concert, and forcible oral copulation. (Id. at p. 291.) The Supreme Court held that the evidence of forcible oral copulation at the preliminary hearing met "the low threshold of proof required to satisfy the corpus delicti rule . . . ." (People v. Jones, supra, 17 Cal.4th at p. 302.) It explained: "The state of the victim's clothing (no underwear or shoes) and the forensic evidence (semen in the victim's vagina and on her external genitalia and anus) indicates multiple sexual acts occurred. . . . This circumstantial evidence of multiple forcible sexual acts sufficiently establishes the requisite prima facie showing of both (i) an injury, loss or harm, and (ii) the involvement of a criminal agency. "Defendant, however, contends that the prosecution failed to establish the corpus delicti of oral copulation because no semen was found in the victim's mouth. In other words, he argues that the lack of evidence of the specific loss or harm to this victim is fatal to the establishment of the corpus delicti. The law's requirements, however, are not so strict." (People v. Jones, supra, 17 Cal.4th at p. 302.) "We have never interpreted the corpus delicti rule so strictly that independent evidence of every physical act constituting an element of an offense is necessary. Instead, there need only be independent evidence establishing a slight or prima facie showing of some injury, loss or harm, and that a criminal agency was involved." (Id. at p. 303.) The California Supreme Court analyzed the corpus delicti rule and the requirement for corroboration in the context of an oral copulation charge. It recited the general principles that the corpus delicti of a crime consists of two elements, the fact of an injury, loss, or harm, and the existence of a criminal agency as its cause. (Jones, supra, 17 Cal.4th at pp. 301 & 302.) It described the corpus delicti of oral copulation: "Section 288a, subdivision (a), defines this crime as 'the act of copulating the mouth of one person with the sexual organ or anus of another person.'" (Jones, at p. 302.) Jones then considered "two previous cases involving application of the rule to a charged sexual assault . . . . In People v. Jennings 1991 53 Cal.3d 334, the body of the victim, a known prostitute, was found in an irrigation canal in a rural area. She was unclothed, and although forensic examination detected she had suffered a broken jaw, the advanced decomposition of her body made determining whether she had been sexually assaulted impossible. More specifically, there was no independent evidence that the defendant ever sexually penetrated the victim. . . . "Despite the absence of any independent evidence of sexual penetration, we found that the trial court properly admitted evidence of the defendant's extrajudicial statement that he had raped the victim before killing her. Although we characterized the independent evidence of rape as '"thin"' (People v. Jennings, supra, 53 Cal.3d at p. 369), we nevertheless concluded that the unclothed condition of the victim's body, its location when found, and the evidence of a broken jaw, considered together, were sufficient to establish the corpus delicti of rape. "People v. Robbins 1988 45 Cal.3d 867, is in accord. The evidence in Robbins showed that the victim, a six-year-old boy, was last seen riding on a motorcycle with an unknown blond man. The boy's skeletal remains were found three months later. The victim's neck had been broken and his body was found unclothed. The defendant had been diagnosed as a pedophile. Although the decomposed remains of the victim could not establish whether he had been sexually assaulted before his death, the defendant made an extrajudicial admission that he abducted the victim and sexually assaulted him before strangling him. We found the trial court properly admitted this confession over a corpus delicti objection. (Id. at pp. 885-886.) 'In view of the nature of the offense and the circumstances of the case (i.e., the body was not discovered for some time, hence it was impossible to verify the sexual conduct by scientific evidence, and there were apparently no eyewitnesses to the crime) we do not believe the corpus delicti rule can be interpreted to call for more; the law does not require impossible showings.' (Id. at p. 886.)" (Jones, supra, 17 Cal.4th at pp. 302-303.)