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	GR No. 165678 2009-07-17	ROSARIO S. PANUNCIO v. PEOPLE CARPIO, J.
public officer or employee who did not take advantage of his official position, of public, private, or commercial documents.[14] 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;