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This case has been cited 3 times or more.

	GR No. 215424 2015-12-09	ADINA B. MANANSALA v. PEOPLE PERLAS-BERNABE, J.
The elements of Falsification of Private Documents under Article 172 (2) of the RPC are: (a) that the offender committed any of the acts of falsification, except those in Article 171 (7) of the same Code; (b) that the falsification was committed in any private document; and (c) that the falsification caused damage to a third party or at least the falsification was committed with intent to cause such damage.[25] On the other hand the elements of Falsification under Article 171 (4) of the RPC are as follows: (a) the offender makes in a public document untruthful statements in a narration of facts; (b) he has a legal obligation to disclose the truth of the facts narrated by him; and (c) the facts narrated by him are absolutely false.[26]
	GR No. 197953 2015-08-05	PEOPLE v. SANDIGANBAYAN BRION, J.
(3) The facts narrated by him are absolutely false.[38]
	GR No. 186030 2012-03-21	NORMA DELOS REYES VDA. DEL PRADO v. PEOPLE REYES, J.
(a) The offender makes in a public document untruthful statements in a narration of facts; (b) The offender has a legal obligation to disclose the truth of the facts narrated by him; and (c) The facts narrated by the offender are absolutely false.[21]