Question juridique clé
Whether the disputed receipt qualifies as a title under Art. 251 CP
Solution extraite
Yes. Because it was a supporting document required to justify the appellant's powers for the land-register filing, it enjoyed enhanced evidentiary value and was not a mere written assertion.
Motifs extraits
A false intellectual forgery requires a document with increased credibility. Given the land-register procedure and the limited verification role of the registrar, the receipt participated in the register's presumption of accuracy and could reasonably be relied on.