What is the test for making a false certificate?

measure of proof than any other crime known to the law, treason alone excepted.' [Citation.] The law looks to 'both the quantity and quality of evidence essential to a conviction of this offense' [citation], and 'positive' in contradistinction to 'circumstantial' evidence is required [citation]. 'It is . . . necessary to have positive testimony as to facts that are absolutely incompatible with the innocence of the accused.' [Citation.] [] '[It] is not sufficient to support the charge of perjury that the accused swears to a material fact that is false, the false swearing must be knowingly and willfully done.' [Citation.] [I]n addition to knowingly making a false statement, there must be a specific intent that the false statement be under oath or penalty of perjury." (People v. Viniegra (1982) 130 Cal.App.3d 577, 585-586.) The element of the statute stating that the defendant must make the statement "willfully" requires proof the defendant made such statement " 'with the consciousness that he did not know that it was true, and with the intent that it should be received as a statement of what was true in fact.' " (People v. Hagen (1998) 19 Cal.4th 652, 663-664.)

"[A] statement made under penalty of perjury is a 'certificate' within the meaning of section 124," and the delivery requirement of section 124 is an element of perjury in cases involving a false certificate. (People v. Griffini (1998) 65 Cal.App.4th 581, 593-594.) Under section 124, "[t]he making of a . . . certificate is deemed to be complete . . . from the time when it is delivered by the accused to any other person, with the intent that it be uttered or published as true."