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California law is instructive. Under the felony-murder rule of section 189 of the Penal Code, a killing committed in either the perpetration of or an attempt to perpetrate robbery is murder of the first degree. This is true whether the killing is wilfull, deliberate and premeditated, or merely accidental or unintentional, and whether or not the killing is planned as a part of the commission of the robbery. (People v. Lookadoo, 66 Cal.2d 307, 314 [57 Cal.Rptr. 608, 425 P.2d 208]; People v. Jennings, 243 Cal.App.2d 324, 328 [52 Cal.Rptr. 329].) People v. Washington, 62 Cal.2d 777, 783 [44 Cal.Rptr. 442, 402 P.2d 130], merely limits the rule to situations where the killing was committed by the felon or his accomplice acting in furtherance of their common design. (See People v. Gilbert, 63 Cal.2d 690, 705 [47 Cal.Rptr. 909, 408 P.2d 365].) The doctrine presumes malice aforethought on the basis of the commission of a felony inherently dangerous to human life. (See People v. Sears, 62 Cal.2d 737, 745 [44 Cal.Rptr. 330, 401 P.2d 938]; People v. Phillips, 64 Cal.2d 574, 582 [51 Cal.Rptr. 225, 414 P.2d 353]; People v. Washington, supra, at p. 780.)
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