The Supreme Court En Banc has promulgated A.M. No. 15-08-02-SC or the “Guidelines for the Proper Use of the Phrase “Without Eligibility for Parole” in Indivisible Penalties” which provides among others that, in cases where death penalty is not warranted, such as this case, there is no need to qualify the sentence of reclusion perpetua with the phrase “without eligibility for parole,” it being understood that convicted persons penalized with an indivisible penalty are not eligible for parole. In this manner, according to the Resolution, will provide uniformity to the Court’s promulgated decisions and resolutions and thus prevent confusion.