How have courts interpreted a grant deed in the context of section 115 of the California Penal Code?

People v. Denman relied on Generes v. Justice Court, supra, 106 Cal.App.3d 678, 681, in which the defendant caused to be recorded a grant deed transferring an easement from herself to herself; the easement was on land the defendant did not own. The appellate court concluded the defendant had violated Penal Code section 115 because the deed was deceptive, even though the defendant had no interest in the easement, and, therefore, the grant deed was technically not false. (Generes v. Justice Court, supra, at p. 682.) "A title searcher encountering the spurious document who acted upon it as genuine would of course be materially deceived." (Ibid.)