Does a defendant have a duty to declare whether a sentence is concurrent or consecutive?

Defendant asks us to vacate the trial court's order stating the terms are to run concurrently. A trial court's duty to impose sentence for a term contains a corresponding mandatory duty to declare whether the term is concurrent or consecutive. ( 669; In re Calhoun (1976) 17 Cal.3d 75, 79-80.) We do not read Alford as eliminating this requirement for counts subject to section 654. The trial court in Alford did not sentence the defendant on the grand theft count; it therefore did not have the opportunity to impose a concurrent or consecutive sentence on that count. Cases are not authority for propositions not therein considered. (Santisas v. Goodin (1998) 17 Cal.4th 599, 620.)

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