In People v. Robertson (1982) 33 Cal.3d 21, the defendant was convicted of two counts of first degree murder with a number of special circumstances. ( People v. Robertson, supra, 33 Cal.3d 21, 30.) At trial, a witness was permitted to testify that appellant had abducted her and forced her to engage in various sexual acts a year prior to the charged incidents. During the attack, appellant threatened to kill her if she told anyone about the incident and told her that he had previously killed two other people. ( Id. at pp. 32-33.) On appeal the defendant argued that his trial counsel was ineffective for failing to object to the testimony regarding appellant's statement that he had previously killed two others. The court stated the testimony was objectionable on the ground that no independent evidence of the corpus delicti of the other crimes was ever introduced. ( Id. at p. 41.) However, the court did not decide the issue based on corpus delicti rule. Rather, the court found that the evidence should have been excluded based on Evidence Code section 352 because its probative value was far outweighed by its prejudicial impact. ( Id. at p. 42.)