In summary, there is only a need to qualify that the accused is not 'eligible for parole' in cases where the imposable penalty should have been death were it not for the enactment of R.A. No. 9346. This is to differentiate cases where the penalty imposable was reduced to reclusion perpetua from cases where the penalty imposed was reclusion perpetua. Here, Gozo is guilty of simple rape, punishable by reclusion perpetua; thus, there was no need to indicate that he was ineligible for parole because accused sentenced to indeterminate penalties are ipso facto ineligible for parole. See People v. Gozo, G.R. No. 225605, July 23, 2018 citing A.M. No. 15-08-02-SC (Guidelines for the proper use of the phrase "without eligibility for parole" in indivisible penalties.) [42] Supra note 26. [43] Id., citing People v. Jugueta, 783 Phil. 806, 840 (2016). [44] Id., citing Nacar v. Gallery Frames, 716 Phil. 267 (2013). Section 5(b), R.A. No. 7610; See also People v. Lutap, supra note 27, citing People v. Caoili, supra note 29. [45] [46] Lutap v. People, supra note 27; citing Quimvel v. People, supra note 31. [47] Id., citing People v. Padlan, G.R. No. 214880, September 6, 2017. [48] G.R. No. 227363, March 12, 2019. [49] Lutap v. People, supra note 27. Source: Supreme Court E-Library This page was dynamically generated by the E-Library Content Management System (E-LibCMS)