K3,3 has 6 vertices and 9 edges, and it is true that 9 ≤ (3 × 6) - 6 = 12. So we cannot use this Corollary to prove that K3,3 is non-planar. We have another Corollary
Let G be a connected planar simple graph with n vertices and e edges, and no triangles. Then e ≤ 2n - 4.
For graph G with f faces, it follows from the handshaking lemma for planar graph that 2e ≥ 3r because the degree of each face of a simple graph is at least 3), so r ≤ $\frac{2}{3}$* e
For graph G with f faces, it follows from the handshaking lemma for planar graphs that 2e ≥ 4r (because the degree of each face of a simple graph without triangles is at least 4), so that r ≤ $\frac{1}{2}$ e.
Proof : Since n - e + r = 2 (Euler's formula)
=> e -n + 2 = r
e - n + 2 ≤ 1/2e
Hence e ≤ 2n - 4