As there is no complex crime of estafa through falsification of private document, 45 it is

important to ascertain whether the offender is to be charged with falsification of a private

document or with estafa. If the falsification of a private document is committed as a means to
commit estafa, the proper crime to be charged is falsification. If the estafa can be committed
without the necessity of falsifying a document, the proper crime to be charged is estafa. Thus,
in People  v. Reyes, 46 the accused made it appear in the time book of the Calamba Sugar Estate
that a laborer, Ciriaco Sario, worked 21 days during the month of July, 1929, when in reality he
had worked only 11 days, and then charged the offended party, the Calamba Sugar Estate, the
wages of the laborer for 21 days. The accused misappropriated the wages during which the
laborer did not work for which he was convicted of falsification of private document.
In U.S.  v. Infante, 47 the accused changed the description of the pawned article on the
face of the pawn ticket and made it appear that the article is of greatly superior value, and
thereafter pawned the falsified ticket in another pawnshop for an amount largely in excess of the
true value of the article pawned. He was found guilty of falsification of a private document.
In U.S.  v. Chan Tiao, 48 the accused presented a document of guaranty purportedly signed by
Ortigas Hermanos for the payment of P2,055.00 as the value of 150 sacks of sugar, and by means
of said falsified documents, succeeded in obtaining the sacks of sugar, was held guilty of
falsification of a private document.
|||  (Batulanon v. People, G.R. No. 139857, [September 15, 2006], 533 PHIL 336-359)

Estafa through Falsification of
Commercial Documents
The elements of falsification of documents under paragraph 1, Article
172 of the Revised Penal Code (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; 46 and (3)
that the falsification was committed in a public, official or commercial document. 47
All these elements were likewise established in this case beyond reasonable doubt.
First, petitioner is a private individual.
Second, petitioner committed one of the acts of falsification under Article
171 of the RPC, i.e., he caused it to appear that Malang applied for the subject loan when he,
in fact, did not do so. Records show that petitioner was able to convince Malang to sign the
loan application, promissory note, and disclosure statement in blank, and together with his
now deceased co-accused Ilagan, processed and approved the loan even if the same was
retracted and discontinued by Malang, not to mention that the documents and requirements
therefor were incomplete. Checks were later on issued and the proceeds thereof withdrawn
under Malang's name, again without the latter's knowledge. Petitioner also made it appear, as
can be gleaned from the Letter dated September 15, 1997 addressed to the BSP signed by
petitioner, that the purported loan application of Malang was approved by RBSM
board of directors and secured by real estate properties. Records, however, show that there
was no such approval from the board nor was there any collateral for the subject loan.
 Third, the falsification was committed in bank loan application, promissory note,
checks and disclosure statement, among others, which are commercial documents.
Commercial documents are, in general, documents or instruments which are "used by
merchants or businessmen to promote or facilitate trade or credit transactions" such as
the above-said documents and instruments. 48
This committed falsification was also established to have been a necessary means to
commit estafa.
In Tanenggee 49 the Court explained that:
The falsification of a public, official, or commercial document may be
a means of committing estafa, because before the falsified document is
actually utilized to defraud another, the crime of falsification has already
been consummated, damage or intent to cause damage not being an
element of the crime of falsification of public, official or commercial
document. In other words, the crime of falsification has already existed.
Actually utilizing that falsified public, official or commercial document to
defraud another is estafa. But the damage is caused by the
commission of estafa, not by the falsification of the document. Therefore,
the falsification of the public, official or commercial document is only a
necessary means to commit estafa.
Estafa is generally committed when (a) the accused defrauded another
by abuse of confidence, or by means of deceit, and (b) the offended party or a
third party suffered damage or prejudice capable of pecuniary estimation."
"[D]eceit is the false representation of a matter of fact, whether by words or
conduct, by false or misleading allegations, or by concealment of that which
should have been disclosed which deceives or is intended to deceive another
so that he shall act upon it to his legal injury." (Citations omitted)
As in this case, the crime of falsification was already consummated, and the
falsified documents were, thereafter, used to defraud the bank to release money purportedly
to Malang.
Records show that the elements of estafa obtain in this case. Petitioner falsely
represented that Malang pursued the loan application and promissory note that were signed in
blank through petitioner's prodding; and orchestrating the whole process until he, with his
now deceased co-accused Ilagan, succeeded in withdrawing the proceeds thereof from
RBSM, coursing them through MRBTI and Land Bank, and thereafter applying the same to
his previous irregular loans also with RBSM. Clearly, petitioner employed deceit to acquire
money, on another person's account, and use the same for his personal use and benefit, which
resulted to the damage and prejudice of the RBSM in the amount of P14,775,000.00.
Again, petitioner could not have acquired the said amount to pay off his previous
loans without the act of falsification. The falsification was, therefore, a necessary means to
commit estafa, and falsification was already consummated even before the
falsified documents were used to defraud the bank. 50
 Thus, the complex crime of estafa through falsification of documents is committed
when the offender commits on a public, official or commercial document any of the
acts of falsification enumerated in Article 171 as a necessary means to commit estafa. 51
The fact that the loan application was actually signed by Malang, not by petitioner,
could not belie his direct hand in perpetrating the crime. To reiterate, it was established that
the loan application was signed by Malang in blank and processed through petitioner's
instructions, to make it appear that Malang purportedly participated in applying for the
subject loan, despite the fact that the purported loan application was withdrawn by Malang. It
was likewise established that it was petitioner's scheme that made the issuance of the check
in the name of Malang, and thereafter, the checks in the names of Rayo and Villacorta,
possible. Hence, as correctly found by the RTC and the CA, one of the
acts of falsification under Article 171 of the RPC, particularly paragraph 2 thereof — causing
it to appear that a person has participated in any act when he did not in fact participate — is
present in this case.
|||  (Soriano v. People, G.R. No. 240458, [January 8, 2020])

Elements of falsification of commercial

documents established.
Falsification of documents under paragraph 1, Article 172 in relation to Article 171 of
the Revised Penal Code (RPC) refers to falsification by a private individual or a public officer or
employee, who did not take advantage of his official position, of public, private or commercial
document. 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; 33 and, (3) that the falsification was committed in a
public, official or commercial document.
All the above-mentioned elements were established in this case. First, petitioner is a
private individual. Second, the acts of falsification consisted in petitioner's (1) counterfeiting or
imitating the handwriting or signature of Tan and causing it to appear that the same is true and
genuine in all respects; and (2) causing it to appear that Tan has participated in an act or
proceeding when he did not in fact so participate. Third, the falsification was committed in
promissory notes and checks which are commercial documents. Commercial documents are, in
general, documents or instruments which are "used by merchants or businessmen to promote or
facilitate trade or credit transactions." 34 Promissory notes facilitate credit transactions while a
check is a means of payment used in business in lieu of money for convenience in business
transactions. A cashier's check necessarily facilitates bank transactions for it allows the person
whose name and signature appear thereon to encash the check and withdraw the amount
indicated therein. 35

Falsification as a necessary means to

commit estafa.
 When the offender commits on a public, official or commercial document any of the
acts of falsification enumerated in Article 171 as a necessary means to commit another
crime like estafa, theft or malversation, the two crimes form a complex crime. Under Article
48 of the RPC, there are two classes of a complex crime. A complex crime may refer to a single
act which constitutes two or more grave or less grave felonies or to an offense as a necessary
means for committing another.
In Domingo v. People, 36 we held:
The falsification of a public, official, or commercial document may be a
means of committing estafa, because before the falsified document is actually
utilized to defraud another, the crime of falsification has already been
consummated, damage or intent to cause damage not being an element of the
crime of falsification of public, official or commercial document. In other
words, the crime of falsification has already existed. Actually utilizing that
falsified public, official or commercial document to defraud another is
estafa. But the damage is caused by the commission of estafa, not by the
falsification of the document. Therefore, the falsification of the public, official
or commercial document is only a necessary means to commit estafa.
"Estafa is generally committed when (a) the accused defrauded another by abuse of
confidence, or by means of deceit, and (b) the offended party or a third party suffered
damage or prejudice capable of pecuniary estimation." 37 "[D]eceit is the false representation
of a matter of fact, whether by words or conduct, by false or misleading allegations, or by
concealment of that which should have been disclosed which deceives or is intended to deceive
another so that he shall act upon it to his legal injury." 38
The elements of estafa obtain in this case. By falsely representing that Tan requested him
to process purported loans on the latter's behalf, petitioner counterfeited or imitated the signature
of Tan in the cashier's checks. Through these, petitioner succeeded in withdrawing money from
the bank. Once in possession of the amount, petitioner thereafter invested the same in Eurocan
Future Commodities. Clearly, petitioner employed deceit in order to take hold of the money,
misappropriated and converted it to his own personal use and benefit, and these resulted to the
damage and prejudice of the bank in the amount of about P43 million.
Taken in its entirety, the proven facts show that petitioner could not have withdrawn the
money without falsifying the questioned documents. The falsification was, therefore, a necessary
means to commit estafa, and falsification was already consummated even before the falsified
documents were used to defraud the bank. The conviction of petitioner for the complex crime of
Estafa through Falsification of Commercial Document by the lower courts was thus proper.
|||  (Tanenggee v. People, G.R. No. 179448, [June 26, 2013], 712 PHIL 310-337)

 COMMERCIAL LAW; COMMERCIAL DOCUMENTS; INCLUDES SALES INVOICE.

— The Sales Invoice is a commercial document. Commercial documents or papers are those
used by merchants or businessmen to promote or facilitate trade or credit transactions. This
Court has previously characterized such documents in this wise: ". . . . In most cases, these
commercial forms [receipts, order slips and invoices] are not always fully accomplished to
contain all the necessary information describing the whole business transaction. The sales clerks
merely indicate a description and the price of each item sold without bothering to fill up all the
available spaces in the particular receipt or invoice, and without proper regard for any legal
repercussion for such neglect. Certainly, it would not hurt if businessmen and traders would
strive to make the receipts and invoices they issue complete, as far as practicable, in material
particulars. These documents are not mere scraps of paper bereft of probative value but vital
pieces of evidence of commercial transactions. They are written memorials of the details of the
consummation of contracts."||| (Monteverde v. People, G.R. No. 139610, [August 12, 2002],
435 PHIL 906-926)

Qualified Theft if no juridical possession in case where the manager has the duty to deposit
the money received to the bank account of the Homeowners Association.
- Mere physical possession – and since money is entrusted – position of confidence
In a long line of cases involving Qualified Theft, this Court has firmly established the
nature of possession by the Bank of the money deposits therein, and the duties being
performed by its employees who have custody of the money or have come into
possession of it. The Court has consistently considered the allegations in the Information that
such employees acted with grave abuse of confidence, to the damage and
prejudice of the Bank, without particularly referring to it as owner of the money deposits, as
sufficient to make out a case of Qualified Theft. For a graphic illustration, we cite Roque v.
People, 6 where the accused teller was convicted for Qualified Theft based on this
Information:
That on or about the 16th day of November, 1989, in the
municipality of Floridablanca, province of Pampanga, Philippines and within
the jurisdiction of his Honorable Court, the above-named accused
ASUNCION GALANG ROQUE, being then employed as teller of the Basa
Air Base Savings and Loan Association Inc. (BABSLA) with office address at
Basa Air Base, Floridablanca, Pampanga, and as such was authorized and
reposed with the responsibility to receive and collect capital contributions
from its member/contributors of said corporation, and having collected and
received in her capacity as teller of the BABSLA the sum of TEN
THOUSAND PESOS (P10,000.00), said accused, with intent of gain, with
grave abuse of confidence and without the knowledge and consent of said
corporation, did then and there willfully, unlawfully and feloniously take,
steal and carry away the amount of P10,000.00, Philippine currency, by
making it appear that a certain depositor by the name of Antonio Salazar
withdrew from his Savings Account No. 1359, when in truth and in fact said
Antonio Salazar did not withdr[a]w the said amount of P10,000.00 to the
damage and prejudice of BABSLA in the total amount of P10,000.00,
Philippine currency. aEcHCD
In convicting the therein appellant, the Court held that:
 [S]ince the teller occupies a position of confidence, and
the bank places money in the teller's possession due to the confidence
reposed on the teller, the felony of qualified theft would be committed. 7
Also in  People v. Sison, 8 the Branch Operations Officer was convicted of the
crime of Qualified Theft based on the Information as herein cited:
That in or about and during the period compressed between January
24, 1992 and February 13, 1992, both dates inclusive, in the City of Manila,
Philippines, the said accused did then and there wilfully, unlawfully and
feloniously, with intent of gain and without the knowledge and consent of the
owner thereof, take, steal and carry away the following, to wit:
Cash money amounting to P6,000,000.00 in different denominations
belonging to the PHILIPPINE COMMERCIAL
INTERNATIONAL BANK (PCIBank for brevity), Luneta Branch, Manila
represented by its Branch Manager, HELEN U. FARGAS, to the damage and
prejudice of the said owner in the aforesaid amount of P6,000,000.00,
Philippine Currency.
That in the commission of the said offense, herein accused acted with
grave abuse of confidence and unfaithfulness, he being the Branch Operation
Officer of the said complainant and as such he had free access to the place
where the said amount of money was kept.
The judgment of conviction elaborated thus:
The crime perpetuated by appellant against his employer, the
Philippine Commercial and Industrial Bank (PCIB), is Qualified Theft.
Appellant could not have committed the crime had he not been holding the
position of Luneta Branch Operation Officer which gave him not only sole
access to the bank vault . . . . The management of the PCIB reposed its trust
and confidence in the appellant as its Luneta Branch Operation Officer, and it
was this trust and confidence which he exploited to enrich himself to the
damage and prejudice of PCIB . . . . 9 cCTAIE
From another end, People v. Locson, 10 in addition to People v. Sison, described the
nature of possession by the Bank. The money in this case was in the possession of the
defendant as receiving teller of the bank, and the possession of the defendant was the
possession of the Bank. The Court held therein that when the defendant, with grave
abuse of confidence, removed the money and appropriated it to his own use without the
consent of the Bank, there was taking as contemplated in the
crime of Qualified Theft. 11
Conspicuously, in all of the foregoing cases, where the Informations merely alleged
the positions of the respondents; that the crime was committed with grave
abuse of confidence, with intent to gain and without the knowledge and consent of the Bank,
without necessarily stating the phrase being assiduously insisted upon by respondents, "of a
relation by reason of dependence, guardianship or vigilance, between the respondents and
the offended party that has created a high degree  of confidence between them, which
 respondents abused," 12 and without employing the word "owner" in lieu of the "Bank"
were considered to have satisfied the test of sufficiency of allegations.
As regards the respondents who were employed as Cashier and
Bookkeeper of the Bank in this case, there is even no reason to quibble on the allegation in
the Informations that they acted with grave abuse of confidence. In fact, the Information
which alleged grave abuse of confidence by accused herein is even more precise, as this is
exactly the requirement of the law in qualifying the crime of Theft.
In summary, the Bank acquires ownership of the money deposited by its clients; and
the employees of the Bank, who are entrusted with the
possession of money of the Bank due to the confidence reposed in them, occupy
positions of confidence. The Informations, therefore, sufficiently allege all the essential
elements constituting the crime of Qualified Theft.
On the theory of the defense that the DOJ is the principal party who may file the
instant petition, the ruling in Mobilia Products, Inc. v. Hajime Umezawa 13 is instructive.
The Court thus enunciated: CacTIE
In a criminal case in which the offended party is the State, the
interest of the private complainant or the offended party is limited to the civil
liability arising therefrom. Hence, if a criminal case is dismissed by the trial
court or if there is an acquittal, a reconsideration of the order of dismissal or
acquittal may be undertaken, whenever legally feasible, insofar as the criminal
aspect thereof is concerned and may be made only by the public prosecutor; or
in the case of an appeal, by the State only, through the OSG. . . . .
|||  (People v. Puig, G.R. Nos. 173654-765, [August 28, 2008], 585 PHIL 555-568)

Increase of Penalty:

SECTION 24. Article 170 of the same Act is hereby amended to read as follows:

"ART. 170. Falsification of legislative documents. — The penalty
of prisión correccional in its maximum period and a fine not exceeding One
million two hundred thousand pesos (P1,200,000) shall be imposed upon any
person who, without proper authority therefor alters any bill, resolution, or
ordinance enacted or approved or pending approval by either House of
Congress or any provincial board or municipal council."
SECTION 25. Article 171 of the same Act is hereby amended to read as follows:
"ART. 171. Falsification by public officer, employee or notary or
ecclesiastic minister. — The penalty of prisión mayor and a fine not to exceed
One million pesos (P1,000,000) shall be imposed upon any public officer,
employee, or notary who, taking advantage of his official position, shall
falsify a document by committing any of the following acts:
"1. Counterfeiting or imitating any handwriting, signature or rubric;
 "2. Causing it to appear that persons have participated in any act or
proceeding when they did not in fact so participate;
"3. Attributing to persons who have participated in an act or
proceeding statements other than those in fact made by them;
"4. Making untruthful statements in a narration of facts;
"5. Altering true dates;
"6. Making any alteration or intercalation in a genuine document
which changes its meaning;
"7. Issuing in an authenticated form a document purporting to be a
copy of an original document when no such original exists, or including in
such a copy a statement contrary to, or different from, that of the genuine
original; or
"8. Intercalating any instrument or note relative to the issuance thereof
in a protocol, registry, or official book.
"The same penalty shall be imposed upon any ecclesiastical minister
who shall commit any of the offenses enumerated in the preceding paragraphs
of this article, with respect to any record or document of such character that its
falsification may affect the civil status of persons."
SECTION 26. Article 172 of the same Act is hereby amended to read as follows:
"ART. 172. Falsification by private individual and use of falsified
documents. — The penalty of prisión correccional in its medium and
maximum periods and a fine of not more than One million pesos (P1,000,000)
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;
"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; and
"3. 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."
|||  (An Act Adjusting the Amount or the Value of Property and Damage on Which a Penalty is
Based, and the Fines Imposed under the Revised Penal Code, Republic Act No. 10951, [August
29, 2017])

For theft:
 SECTION 81. Article 309 of the same Act is hereby amended to read as follows:
"ART. 309. Penalties. — Any person guilty of theft shall be punished
by:
"1. The penalty of prisión mayor in its minimum and medium periods,
if the value of the thing stolen is more than One million two hundred thousand
pesos (P1,200,000) but does not exceed Two million two hundred thousand
pesos (P2,200,000); but if the value of the thing stolen exceeds the latter
amount, the penalty shall be the maximum period of the one prescribed in this
paragraph, and one (1) year for each additional One million pesos
(P1,000,000), but the total of the penalty which may be imposed shall not
exceed twenty (20) years. In such cases, and in connection with the accessory
penalties which may be imposed and for the purpose of the other provisions of
this Code, the penalty shall be termed prisión mayor or reclusion temporal, as
the case may be.
"2. The penalty of prisión  correccional in its medium and maximum
periods, if the value of the thing stolen is more than Six hundred thousand
pesos (P600,000) but does not exceed One million two hundred thousand
pesos (P1,200,000). SDHTEC
"3. The penalty of prisión correccional in its minimum and medium
periods, if the value of the property stolen is more than Twenty thousand
pesos (P20,000) but does not exceed Six hundred thousand pesos (P600,000).
"4. Arresto mayor in its medium period to prisión correccional in its
minimum period, if the value of the property stolen is over Five thousand
pesos (P5,000) but does not exceed Twenty thousand pesos (P20,000).
"5. Arresto mayor to its full extent, if such value is over Five hundred
pesos (P500) but does not exceed Five thousand pesos (P5,000).
"6. Arresto mayor in its minimum and medium periods, if such value
does not exceed Five hundred pesos (P500).
"7. Arresto menor or a fine not exceeding Twenty thousand pesos
(P20,000), if the theft is committed under the circumstances enumerated in
paragraph 3 of the next preceding article and the value of the thing stolen does
not exceed Five hundred pesos (P500). If such value exceeds said amount, the
provisions of any of the five preceding subdivisions shall be made applicable.
"8. Arresto menor in its minimum period or a fine of not exceeding
Five thousand pesos (P5,000), when the value of the thing stolen is not over
Five hundred pesos (P500), and the offender shall have acted under the
impulse of hunger, poverty, or the difficulty of earning a livelihood for the
support of himself or his family."
|||  (An Act Adjusting the Amount or the Value of Property and Damage on Which a Penalty is
Based, and the Fines Imposed under the Revised Penal Code, Republic Act No. 10951, [August
29, 2017])
 SECTION 85. Article 315 of the same Act, as amended by Republic Act No.
4885, Presidential Decree No. 1689, and Presidential Decree No. 818, is hereby further
amended to read as follows:
"ART. 315. Swindling (estafa). — Any person who shall defraud
another by any of the means mentioned hereinbelow shall be punished by:
"1st. The penalty of prisión correccional in its maximum period
to prisión mayor in its minimum period, if the amount of the fraud is over
Two million four hundred thousand pesos (P2,400,000) but does not exceed
Four million four hundred thousand pesos (P4,400,000), and if such amount
exceeds the latter sum, the penalty provided in this paragraph shall be
imposed in its maximum period, adding one year for each additional Two
million pesos (P2,000,000); but the total penalty which may be imposed shall
not exceed twenty years. In such cases, and in connection with the accessory
penalties which may be imposed and for the purpose of the other provisions of
this Code, the penalty shall be termed prisión mayor or reclusion temporal, as
the case may be.
"2nd. The penalty of prisión correccional in its minimum and medium
periods, if the amount of the fraud is over One million two hundred thousand
pesos (P1,200,000) but does not exceed Two million four hundred thousand
pesos (P2,400,000).
"3rd. The penalty of arresto mayor in its maximum period
to prisión correccional in its minimum period, if such amount is over Forty
thousand pesos (P40,000) but does not exceed One million two hundred
thousand pesos (P1,200,000).
"4th. By arresto mayor in its medium and maximum periods, if such
amount does not exceed Forty thousand pesos (P40,000): Provided, That in
the four cases mentioned, the fraud be committed by any of the following
means:
"1. With unfaithfulness or abuse of confidence, namely:
"(a) By altering the substance, quantity, or quality of anything of value
which the offender shall deliver by virtue of an obligation to do so, even
though such obligation be based on an immoral or illegal consideration.
"(b) By misappropriating or converting, to the prejudice of another,
money, goods, or any other personal property received by the offender in trust
or on commission, or for administration, or under any other obligation
involving the duty to make delivery of or to return the same, even though such
obligation be totally partially guaranteed by a bond; or by denying having
received such money, goods, or other property.
"(c) By taking undue advantage of the signature of the offended party
in blank, and by writing any document above such signature in blank, to the
prejudice of the offended party or any third person.
 "2. By means of any of the following false pretenses or
fraudulent acts executed prior to or simultaneously with the commission of the
fraud:
"(a) By using fictitious name, or falsely pretending to possess power,
influence, qualifications, property, credit, agency, business or imaginary
transactions, or by means of other similar deceits.
"(b) By altering the quality, fineness or weight of anything pertaining
to his art or business.
"(c) By pretending to have bribed any Government employee, without
prejudice to the action for calumny which the offended party may deem
proper to bring against the offender. In this case, the offender shall be
punished by the maximum period of the penalty.
"(d) By postdating a check, or issuing a check in payment of an
obligation when the offender had no funds in the bank, or his funds deposited
therein were not sufficient to cover the amount of the check. The failure of the
drawer of the check to deposit the amount necessary to cover his check within
three (3) days from receipt of notice from the bank and/or the payee or holder
that said check has been dishonored for lack or insufficiency of funds shall
be prima facie evidence of deceit constituting false pretense or fraudulent act.
"Any person who shall defraud another by means of false pretenses or
fraudulent acts as defined in paragraph 2(d) hereof shall be punished by:
"1st. The penalty of reclusion temporal in its maximum period, if the
amount of fraud is over Four million four hundred thousand pesos
(P4,400,000) but does not exceed Eight million eight hundred thousand pesos
(P8,800,000). If the amount exceeds the latter, the penalty shall be reclusion
perpetua.
"2nd. The penalty of reclusion temporal in its minimum and medium
periods, if the amount of the fraud is over Two million four hundred thousand
pesos (P2,400,000) but does not exceed Four million four hundred thousand
pesos (P4,400,000).
"3rd. The penalty of prisión mayor in its maximum period, if the
amount of the fraud is over One million two hundred thousand pesos
(P1,200,000) but does not exceed Two million four hundred thousand pesos
(P2,400,000).
"4th. The penalty of prisión mayor in its medium period, if such
amount is over Forty thousand pesos (P40,000) but does not exceed One
million two hundred thousand pesos (P1,200,000).
"5th. By prisión mayor in its minimum period, if such amount does
not exceed Forty thousand pesos (P40,000). AScHCD
"3. Through any of the following fraudulent means:
"(a) By inducing another, by means of deceit, to sign any document.
 "(b) By resorting to some fraudulent practice to insure success in a
gambling game.
"(c) By removing, concealing or destroying, in whole or in part, any
court record, office files, document or any other papers."
|||  (An Act Adjusting the Amount or the Value of Property and Damage on Which a Penalty is
Based, and the Fines Imposed under the Revised Penal Code, Republic Act No. 10951, [August
29, 2017])