1. That a physician or surgeon has issued a false medical certificate, or a public officer
   has issued a false certificate of merit or service, good conduct, or similar
   circumstances, or a private person had falsified any of said certificates;
2. That the offender knew that the certificate was false; and
3. That he used the same.

CERTIFICATE - any writing by which testimony is given that a fact has or has not taken place

When any of false certificates mentioned in Article 174 is used in judicial proceedings,
Article 172 does not apply because it is limited only to those false documents embraced
in Articles 171 and 172.