Falsification

Even the presumption that the person who is benefited by the falsified document is presumed to be the author, cannot be applied in this case. Petitioner was not directly benefited by the certificate. It must be pointed out here that the said certification benefited First United Construction Corporation which was granted the construction project, and petitioner was merely an officer of said company and any benefit he may have received from said project would only have been incidental (Dizon v. People, G.R. No. 144026, June 15, 2006).