It would be 3 !
Find all the factors of 3, 9 , and 12 and see that one that are alike FIRST
Factors :
Factors of 3
3, 6, 9, 12, 15, 18
Factors of 9
9, 18, 27, 36, 45, 54
Factors of 12
12, 24, 36, 48, 60
They can all divide by 3 making 3 the greatest common factor