Falsification under par. 1, Art. 172

The elements of falsification of documents under paragraph 1, Article 172 of the RPC are:

1. that the offender is a private individual or a public officer or employee who did not take advantage of his official position;
2. that he committed any of the acts of falsification enumerated in Article 171 of the RPC; and
3. that the falsification was committed in a public, official or commercial document. (Panuncio v. People, G.R. No. 165678, July 17, 2009)