ARGUMENTS

1. Defense of Insanity

1.1. Accused not appreciated the nature of the wrongful acts

1.2. Inability occured at the time of the commission of the crime

1.2.1. Does not act during lucid interval

1.3. The act is a result of a mental illness

1.3.1. Schizophrenia

1.3.2. Mental health issues

2. Plea-bargaining

2.1. Guilty

2.1.1. Homicide (Reclusion Temporal- 12 yrs and 1 day to 20 yrs)

2.1.1.1. Bail

2.1.2. Admit to lesser or lighter offense

2.1.2.1. Bail

2.2. Not guilty

2.2.1. Case will proceed

3. Arrest by officer is not proper

3.1. Miranda rights not read

3.2. Not informed of the nature and cause of the accusation

4. Prosecutor handling the case was not authorized

4.1. Prosecutor of other jurisdiction handled the case

5. Arrest without warrant

5.1. Arresting officer failed to secure a warrant in court

5.2. Not falling under Sec. 5, Rule 113 of ROC

5.2.1. Not in flagrante delicto

5.2.2. Not hot pursuit

5.2.3. Not escaped prisoner