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Statute
Philippine Revised Penal Code
Article
Art. 172
Topic
Falsification by private individual and use of falsified documents
Status
In force, as amended
Year
1930
Cited by
Multiple Supreme Court decisions

The provision

Art. 172. Falsification by private individual and use of falsified documents. — The penalty of prision correccional in its medium and maximum periods and a fine of not more than One million pesos (₱1,000,000) shall be imposed upon:

1. Any private individual who shall commit any of the falsifications enumerated in the next preceding article in any public or official document or letter of exchange or any other kind of commercial document; and

2. Any person who, to the damage of a third party, or with the intent to cause such damage, shall in any private document commit any of the acts of falsification enumerated in the next preceding article.

Any person who shall knowingly introduce in evidence in any judicial proceeding or to the damage of another or who, with the intent to cause such damage, shall use any of the false documents embraced in the next preceding article, or in any of the foregoing subdivisions of this article, shall be punished by the penalty next lower in degree.

Intellegal Wiki · In plain terms

Punishes a private individual who falsifies a public, official, or commercial document, and anyone who falsifies a private document to another's damage, with imprisonment (prision correccional in its medium and maximum periods) and a fine of up to ₱1,000,000. Knowingly introducing or using such false documents in court or to another's damage carries the penalty next lower in degree.

An editorially maintained plain-language explanation of this provision — not legal advice.

Intellegal Wiki · How the courts apply it

In Sunga v. People, the Supreme Court held: Denied the petition and affirmed the conviction with modification, holding that one found in possession of and using a forged document is presumed to be the forger, a presumption the accused failed to overcome, and appreciating old age as a mitigating circumstance in fixing the indeterminate penalty for falsification under Article 172 of the Revised Penal Code.

One leading Supreme Court case applying this provision.

As amended: the fines and monetary thresholds in this provision reflect the amendments introduced by RA 10951 (2017).

Cases applying this article

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Reviewed by the Intellegal Legal Team for currency against amending laws and Supreme Court jurisprudence.

Research aid — not legal advice. Verify the current text against the Official Gazette. Provisions may have been amended or repealed. Using this page creates no attorney-client relationship. For legal advice, consult a Philippine lawyer.