How have subsequent judgments in a criminal case been determined to run concurrently?

Subsequent judgments are deemed to run concurrently only if the court neglects to state "at the time of pronouncement of the second or other judgment," the manner in which the sentences are to be served. (e.g., see People v. Ewing (1961) 198 Cal.App.2d 364, 18 Cal.Rptr. 9.) Here, there was no failure of the trial court either at the April 25, 1983, sentencing hearing, or at the March 21, 1984, sentencing hearing, to determine that the subsequent judgments shall run consecutively. The manner in which the court imposed consecutive sentences at both hearings was correct. It is good practice for the court to say, for example, that sentence number four is consecutive to sentences number one, two and three. It is also sufficient for the court to state, as it did on April 23, 1983, that sentence number two is consecutive to sentence number one, sentence number three is consecutive to sentence number two, and so on. This is tantamount to determining how the sentences shall run in relation to each other, because sentence number three is also necessarily consecutive to sentence number one and two. Accordingly, we find that the trial court properly designated that petitioner's sentences were to be served consecutively. ¹