The Never Ending Democratization of the Philippines 107 i.e., the development of capabilities (Sen 1999: 36). These capabilities should improve the quality of life of the people marked by longevity, knowledge, and better standards of living (Dimensions of the UNDP's Human Development Index. (See Philippine Human Development Report 2008/2009: 101). The Rationale of Separation of Powers and System of Checks and Balances The core of the Presidential form of government is the co-equal branches of government—the executive, legislative and judicial. By vesting separate powers to each of them, no branch of government could dominate the others. Through the system of checks and balances, “power is checked by power that is meant to prevent the rise of tyranny” (Montesquieu, 1748: 69). In this scheme, each branch of government is vested with exclusive power. The boundaries of these powers, however, are not definite. In many cases, executive power is limited by legislative power. Some common examples include the executive power to appoint which must confirmed by Congress' Commission on Appointments. Another is the power of the President to enter into a treaty that has to be ratified by the Senate. The legislative power of Congress, on the other hand could be limited by executive power to veto a bill. And the Supreme Court, in accordance with its power of judicial review, could nullify and declare unconstitutional a statute or an executive order. This interaction of check and balance is the distinctive characteristic of our country's constitutional structure. This dynamic could lead to impasse and inaction, a common criticism against Presidentialism. But in an influential decision of the American Supreme Court, the rationale of separation of powers is described thus: The doctrine of separation of power was adopted by the Convention of 1787 not to promote efficiency but to preclude the exercise of arbitrary power. The purpose was not to avoid friction, but by means of the inevitable friction incident to the distribution of powers among three departments, to save the people from autocracy. (Justice Brandeis, Myers v. United States, 272 US 52 293 in Sinco 1962: 129). Separation of powers was never meant to provide governmental efficiency because it is designed to create friction among the departments of government. This friction, even if it leads to impasse or inaction, should not be avoided. It is this friction among the branches of government that shield the people from abuse of power. But once a policy decision is reached through the dynamic of checks and balances, the efficient implementation of policies becomes the task of the professional civil service.