Can estafa be committed through falsification of documents?
The falsification of a public 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 documents. The damage to another is caused by the commission of estafa, not by the falsification of the document, hence, the falsification of the public, official or commercial document is only a necessary means to commit the estafa.
