In In re Cowen (1946) 27 Cal. 2d 637, the California Supreme Court determined that section 669 was enacted to address "the serving of multiple sentences only in so far as concerns whether such sentences should operate concurrently or cumulatively, not to require that for all purposes, when consecutive sentences are directed, the defendant shall be regarded as imprisoned on only one charge at a time." (27 Cal. 2d at p. 648.) On that basis, the court determined that "consecutive sentences, even if regarded as separate and distinct for some purposes, necessarily coalesce into one aggregate term of confinement during which the prisoner is continuingly restrained of his liberty." (27 Cal. 2d at p. 647.) This view was consistent with its prior ruling in People v. McNabb, the court noted, since "it was necessarily held that the defendant was 'undergoing a life sentence' even though he had not yet completed his fixed term sentence." (27 Cal. 2d at p. 648.)