In what circumstances will a defendant be convicted of violating section 132 of the California Penal Code for using a falsified check in a civil trial?

In People v. Hooper (1935) 10 Cal.App.2d 332, 51 P.2d 1131, the defendant was convicted of violating section 132 based on his use of a falsified check in a civil trial to show that he did not owe rent. (Id. at pp. 333334, 51 P.2d 1131.) The defendant argued on appeal that the evidence was insufficient to show that he offered the falsified check in evidence during the civil trial because it was never formally introduced into evidence. (Id. at p. 334, 51 P.2d 1131.) The court disagreed, stating: It is true that the record does not disclose that the check was ever marked as an exhibit in the civil case, and the court reporter at that trial could not discover from his notes that it was ever formally introduced in evidence. But the check was produced in the municipal court by appellant's attorney, appellant there testified as to the check and the disputed endorsement, it was marked for identification, was

[239 Cal.App.4th 1341]