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7/31/2019 Comparative Analysis of the Governments of PH, US, Germany, FR, RU, and UK
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Mariano Marcos State University
COLLEGE OF TEACHER EDUCATION
Laoag City
AComparison of the Governmentsof the Philippines, the United States of America,
the United Kingdom,Germany, France, and Russia
Prepared By:
Jayson C. Quinones
BSE III-B
Prepared For:
Prof. Arnora E. Rasos
Professor
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March 2012
General InformationThe Philippines United States of America United Kingdom Germany France Russia
1. Official Name Republic of thePhilippines
The United States of
America
United Kingdom of Great
Britain and Ireland
Federal Republic of
Germany
The French Republic The Russian Federat
2. Capital Manila Washington, D.C London Berlin Paris Moscow3. Currency
(Exchange rate as
of Mar 2012)
Philippine Peso
1 USD = 43.01 PHP
US Dollar
1 USD = 1 USD
Pound sterling
1 USD = 0.64 GBP
Euro
1 USD = 0.76 EUR
1 USD = 0.76 EUR 1 USD = 29.51 RUB
4. GDP per capita(PPP, 2011, data
from the IMF)
$ 4,111 $ 48,147 $ 35 974 $ 37,935 $ 35,048 $ 16,867
5. National Anthem Lupang Hinirang Star-Spangled Banner God Save the Queen(King)
Das Lied der Deutschen Le Marseillaise Gosudarstvenny Gim
Rossiyskoy Federatsi
6. Type ofGovernment
Unitary presidential
constitutional republic
Federal presidential
constitutional republic
Unitary parliamentary
constitutional monarchy
Federal parliamentaryconstitutional republic
Unitary semi-
presidential
constitutional republic
Federal semi-
presidential republic
The Executive Branch
Head of State
The Philippines United States of America United Kingdom Germany France Russia
1. Title and Holderof Title
President
Benigno S. Aquino III
President
Barack Obama
The British Monarch
Elizabeth II
Bundesprsident (Federa
l President)
Horst Khler
President
Nicolas Sarkozy
President
Dmitry Medvedev
2. Means ofElection /
Selection
Direct vote Electoral College Hereditary succession Federal Convention Direct vote Direct vote
3. Qualificationsa) Citizenshipb) Agec) Residency
A natural-born citizen of their respective countries- None A German citizen A French national A Russian citizen
Aged 40 and above on
election day
Aged 35 and above - None Aged 40 and above Aged 23 and above Aged 35 and aboveResident for at least 10 Resident for at least 14 None None None Permanently residing
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d) Othersyears prior to the
election
years prior to the election the Russian Federati
for at least 10 years
Literate Registered voter
None Born in wedlock ofparents who are
legitimate heirs to the
throne
Protestant
Anyone who isentitled to vote in
Bundestag elections
Registered voter Must be on the
electoral role in their
commune of
residence Must be in full
possession of civic
rights
-None
4. Term of Officea) Duration
of Term
6 years 4 years Lifetime 5 years 5 years 4 years
b) Numberof Terms
Allowed
1 2 Lifetime 2 2 2
5. Powers Nominate andappoint (with the
consent of the
Commission on
Appointments) the
heads of the
executive
departments,
ambassadors, other
public ministers and
consuls, or officers
of the armed forces
from the rank of
colonel or naval
captain, and other
officers whoseappointments are
vested in him in the
Appoints theSecretaries of
Executive
Departments, heads of
independent federal
commissions, federal
judges, ambassadors,
and other federal
offices but with the
approval of the Senate
Appointees for theVice Presidency must
be ratified by the
Congress in a majority
vote.
Appoint a PrimeMinister
Proposes an individualto become a Federal
Chancellor
Appoints federaljudges, federal civil
servants and military
officers. All such
appointments require
the counter-signature
of either the
chancellor or the
relevant cabinet
minister
Names the PrimeMinister, but cannot
dismiss him
Names otherministers, but can
dismiss them with
the assent of the
Prime minister
Names mostofficials with the
assent of the
Cabinet
Appoints anddismisses the
Cabinet
Appoints andremoves the hig
commander of t
Armed Forces
Appoints justicesfederal district co
Appoints and recRussias
ambassadors wit
the consultation
the Legislature
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Constitution
Commander-in-Chief of the Armed
Forces
Approve or vetolaws passed by the
Congress Issuance of
Executive Orders
Grants the followingafter conviction by
final judgement,except in cases of
impeachment:
pardons cancellation
of sentence;
reprieves postponeme
nt of
execution to
a later date;
and commutatio
ns
Commander-in-Chiefof the Armed Forces
Approve or veto lawspassed by the
Congress Issuance of Executive
Orders
Grant unlimitedpardons and
clemencies, except in
cases of impeachment
Conclude treaties with
Commander-in-Chiefof the Armed Forces
Grants Royal Assentfor a bill to become a
law
Approve or veto lawspassed by the
Bundestag
Grant pardons if theperson concerned had
been convicted under
federal jurisdiction
Commander-in-Chief of the Armed
Forces
Promulgates orveto laws
The President canrequest another
reading of it in the
Parliament
Issue decrees andirectives withou
legislative review
Schedulereferendums, sub
draft laws to the
Duma, and
promulgating
Federal Laws
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reduction of
sentence
Conclude treatieswith the approval of
2/3 of the Senate
the approval of 2/3 of
the Senate
Treaties on foreigntrade are ratified by
the Houses of the
Congress
6. Unique Powers Contract orguarantee foreign
loans on behalf of
the Republic of the
Philippines with the
prior concurrence of
the Monetary Board Declare martial law
or suspension of the
privilege of writ of
habeas corpus for 60
days, which may be
revoked or extended
by Congress within
48 hours, or by the
Supreme Court
within 30 days.
Head of the Church ofEngland
Dissolution of theBritish Parliament
whenever he/she
wishes
Dissolution of theBundestag
Checks theconstitutionality of
legislation
Dissolution of theNational Assembly
Order the use ofnuclear weapons
Declare a nationregional state of
martial law as we
a state of emerg
Head of Government
1. Title and Holderof Title
- The Head of State and the Head ofGovernment is one
Prime Minister
David Cameron
Bundeskanzler (Federal
Chancellor)
Angela Merkel
Prime Minister
Franois Fillon
Prime Minister
Vladimir Putin
2.
Means ofElection /
Selection
-The Head of State and the Head ofGovernment is one Appointed by theMonarch Proposed by thePresident, elected by
members of the
Bundestag without debate
Nominated by themajority party or
coalition in the National
Assembly and
Appointed by thePresident with the
consent of the Duma
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appointed by the
President for an
indefinite term
3. Qualifications
a) Citizenship
b)
Agec) Residence
d) Others
- The Head of State and the Head ofGovernment is one
- No legal specifications - None - A Russian cit- None
4. Term of Officea. Duration of
Term
- The Head of State and the Head ofGovernment is one
Depends on the Queens
discretion or until
resignation
5 years 5 years Depends on the
Presidents discretio
until resignationb. Number ofTerms
2 2
5. Powers - The Head of State and the Head ofGovernment is one
- Creates a Cabinetcomposed with the
support of the House
of Commons
- Obtain theappointment, dismissal
or nominal resignation
of any other minister
- Holds power over thedeployment and
disposition of British
- Determines theFederal Cabinet
- Recommends theappointment and
dismissal of Cabinet
Ministers
- Set the number ofministers and dictate
their duties
- RecommendsMinisters to the
President
- Sets outMinisters' duties
and
responsibilities
- Manages thedaily affairs of
government
- Issues decrees
- Responsible fornational
defense.
- submits to thePresident propos
on the structure
functions of the
central institutio
the executive bra
(e.g. ministries a
federal agencies
- nominates the vprime ministers,
federal ministers
other officers an
presents them to
President
- distributes dutieamong members
the Government
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forces, and the
declaration of war with
the Secretary of State
for Defence
6. Unique Powers - formally advises theSovereign on the
appointment of
Archbishops and
Bishops of the Church
of England
- Issues formal policyguidelines which
serve as basis for
introduction of
policies at the
ministerial level
- Heads the sessioof the Governme
and its Presidium
where he has the
decisive vote
- Represents theGovernment as a
institution in fore
relations and ins
the country
- signs the acts of Government
-The Vice-Presidency
The Philippines United States of America United Kingdom Germany France Russia1. Holder of Title Jejomar Binay Joe Biden N/A2. Means of
Election /
Selection
Direct vote Electoral College
3. Qualificationsa) Citizenshipb) Agec) Residencyd) Others
A natural-born citizen of their respective countries N/A
Aged 40 and above on
election day
Aged 35 and above
Resident for at least 10
years prior to the
election
Resident for at least 14
years prior to the election
Literate
Registered voter
None
4. Term of Officee) Duration of 6 years 4 years N/A
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Term
f) Number ofTerms
Allowed
1 Unlimited
5. Powers Replace the President in case of death, permanentdisability, removal from office, or resignation of the
President.
N/A
Can be appointed bythe President to any
position in the
Cabinet without
confirmation of the
Commission on
Appointments
President of theSenate
Presides over countingand presentation of
the votes of the
Electoral College
The Cabinet
Function The Philippines United States of America United Kingdom Germany France Russia
Collective Name Cabinet of thePhilippines
Cabinet of the UnitedStates of America
Cabinet of the UnitedKingdom
Cabinet of Germany The French Cabinet Council of Ministers
Economy Department of
Agrarian Reform
Virgilio De Los Reyes
Department of
Agriculture
Proceso Alcala
Department of
BudgetManagement
Florencio Abad
Federal Ministry for
Food, Agriculture
and Consumer
Protection
Ilse Aigner
Ministry of
Agriculture and
Fishing
Bruno La Maire
Ministry ofBudget, Public
Accounts, Civil
Service, & State
Ministry of
Agriculture
Yelena Borisovna
Skrynnik
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Department of
Energy
Jose Rene Almendras
Department of
Finance
Cesar Purisima
Department of
Tourism
Ramon Jimenez
Department of
Trade and Industry
Gregory Domingo
Department of
Treasury
Timothy Geitner
Department of
Commerce
John Bryser
Department of
Housing and UrbanDevelopment
Shaun Donovan
Department of
Energy and Climate
Change
Ed Davey
Her Majesty's
Treasury
George Osborne
Department for
Business, Innovation
and SkillsVincent Cable
Federal Ministry of
FinanceWolfgang Schuble
Federal Ministry of
Economics and
TechnologyPhilipp Rsler
Federal Ministry for
Economic
Cooperation and
Development
Dirk Niebel
Reform & Govt.
Spokesman
Valerie Pecresse
Ministry of
Economy, Industryand Employment
Francois Baroin
Ministry of Ene
Sergey Ivanovich
Shmatko
Ministry of Fina
Anton Germanov
Siluanov
Ministry of
Economic
DevelopmentElvira Sakhipzad
Nabiullina
Ministry of
Industry & Trad
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Department For
International
Development
Andrew Mitchell
Environmental
Management
Department of
Environment and
Natural Resources
Ramon Paje
Department of
Interior
Ken Salazar
Department for
Environment, Food
and Rural Affairs
Caroline Spelman
Federal Ministry for
the Environment,
Nature Conservation
and Nuclear SafetyNorbert Rttgen
Ministry of
Ecology,
Sustainable
Development,
Transport and
Housing
Nathalie Kosciusko-
Morizet
Ministry of Nat
Resources &
Ecology
Yuriy Petrovich
Trutnev
Government Department of
Interior and Local
Government
Jesse Robredo
Department for
Communities and
Local Government
Eric Pickles
Ministry of the
Interior
Claude Guant
Ministry of Towns
Maurice Leroy
Ministry of Sports
David Douillet
Ministry of Inte
Affairs
Rashid Gumarov
Nurgaliyev
Ministry ofRegional
Development
Viktor Fedorovic
BASARGIN
Ministry of Civi
Defense,
Emergencies, &Natural Disaste
Sergey
Kuzhugetovich
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Shoygu
Law Enforcement Department of
Justice
Leila de Lima
Attorney General's
Office
Dominic Grieve
Ministry of Justice
Kenneth Clarke
Federal Ministry of
Justice
Sabine Leutheusser-
Schnarrenberger
Ministry of Justice
Michel Mercier
Ministry of Just
Aleksandr
Vladimirovich
Konovalov
Social Welfare Department of
Health
Enrique Ona
Department of
Social Welfare and
Development
Corazon Soliman
Department of
Labor and
Employment
Rosalinda Baldoz
Department of
Education
Armin Luistro
Department of
Health and Human
Services
Kathleen Sebelius
Department of Labor
Hilda Solis
Department of
Health
Andrew Lansley
Department for
Education
Michael Gove
Federal Ministry of
Education and
Research
Annette Schavan
Federal Ministry of
Health
Daniel Bahr
Federal Ministry of
Family Affairs, Senior
Citizens, Women and
Youth
Kristina Schrder
Federal Ministry for
Labour and Social
Affairs
Ursula von der Leyen
Minister of Labour,
Social Relations,
Family and
Solidarity
Xavier Bertrand
Ministry of
National
Education, Youth,
and Sport
Luc Chatel
Ministry of HigherEducation and
Research
Laurent Wauquiez
Ministry of Hea
& Social
Development
Tatyana Aleksey
Golikova
Ministry of
Education &
Science
Andrey
Aleksandrovich
Fursenko
Ministry of Cult
Aleksandr
Alekseyevich
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Department of
Veterans Affairs
Eric Shinseki
Department for
Work and Pensions
Iain Duncan Smith
Department for
Culture, Media and
Sport
Jeremy Hunt
Avdeyev
Ministry of Spo
Tourism, & You
Policy
Vitaliy Leontyevi
Mutko
Ministry Of
Communication
Mass Media
Igor Olegovich
Shchegolev
Others Department of
Foreign Affairs
Albert del Rosario
Department of
National Defense
Voltaire Gazmin
Department of
Department of State
Hillary Clinton
Department of
Defense
Leon Panetta
Department ofHomeland Security
Janet Napolitano
Foreign and
Commonwealth
Office
William Hague
Federal Foreign
Office
Guido Westerwelle
Federal Ministry of
Defence
Thomas de Maizire
Federal Ministry ofthe Interior
Hans-Peter Friedrich
Ministry of Foreign
and European
Affairs
Alain Jupp
Ministry of
Defense and
Veterans Affairs
Grard Longuet
Ministry of Fore
Affairs
Sergey Viktorovi
Lavrov
Ministry of Def
Anatoliy
Eduardovich
Serdyukov
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Science and
Technology
Mario Montejo
Department of
Public Works and
Highways
Rogelio Singson
Department of
Transportation and
Communications
Manuel Roxas II
Department of
Transportation
Ray LaHood
Department for
Transport
Justine Greening
Government
Equalities Office
Theresa May
Federal Ministry of
Transport, Building
and Urban
Development
Peter Ramsauer
Ministry of Culture
and
CommunicationFrdric Mitterrand
Ministry of
Transportation
Igor Yevgenyevic
Levitin
The Government of the Philippines
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The Government of the United States of America
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The Government of Germany
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The Government of France
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The Government of Russia
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The Legislative Branch
The Upper House
The Philippines United States of America United Kingdom Germany France Russia
1. Name Senate Senate House of Lords Bundesrat Snat (Senate) Sovet Federatsii(Federation CounciRussia)
2. Means ofElection /
Selection of its
Members
Direct vote Direct vote The Queen selects from
persons recommended by
the House of Lords
Appointments
Commission
Delegated by their
respective state
government
Elected by the:
Members of theNational Assembly
for the department members of
the dpartement'sGeneral Council and
Regional Council. Delegates from
municipal councils
Chosen by territorial
politicians
3. Qualificationsa.Citizenship
b.Agec.Residency
d.Others
A natural-born citizen of
the Philippines
A US citizen for at least 9
years
Citizens of the UnitedKingdom, Ireland or
any Commonwealth
nation
N/A A French national A Russian citizen
Aged 35 and above Aged 30 and above Aged 21 and above Aged 30 and above Aged 30 and aboveA resident of the
Philippines for at least 2
years prior to the
elections
A resident of the state he
intends to represent
None None Permanently residingthe Russian Federati
for at least 10 years
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Literate Registered voter
None Not a subject of theBankruptcy
Restrictions Order (in
England and Wales),
not adjudged
bankrupt (in Northern
Ireland), or does not
have a sequesteredestate (in Scotland)
Not serving a prisonterm for high treason
Registered voter Must be in full
possession of civic
rights
-None
4. Term of Officea.Duration of
Term
6 years 6 years Lifetime Unlimited; stays until a
replacement is selected by
the state government
6 years 4 years
b.Number ofTerms
Allowed
2 Unlimited Lifetime Unlimited 2
b. Powers Passage of laws Confirmation ofpresidential
appointments
Passage of laws Venue where theFederal Government
must present itslegislative initiatives
before it can pass a
proposal to the
Bundestag
Approves or rejectslegislation
Further debates approves bills
previously approby the State Dum
Approving thepresident's
nomination of
judges of the
Constitutional Co
of the Russian
Federation, of th
Supreme Court o
the Russian
Federation, of th
Highest Arbitrati
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Election of thepresident in case of a
tie
Conviction ofimpeachment
Official concurrenceon a treaty
Designation of thevice-president as
acting president
Overriding apresidential veto
Tries impeachmentcases for federal
officials referred to it
by the House
Ratification of treaties
Scrutinizesgovernment actions
and policies
Veto legislationpassed by the
Bundestag Scrutinizesgovernment
policies
VotesConstitutional
amendments
Representscounties, districts,
Court of the Rus
Federation
Approving thepresident's
nomination of th
Attorney Genera
the Russian
Federation Appointment of
Deputy Chairma
and half of the
auditors of the
Accounting Cham
Impeachment ofRussian presiden
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and states
Specializes inforeign affairs,
including European
integration
Approval of thePresidents decre
declare martial la
and state of
emergency
Deciding on thepossibility of usi
the Armed Force
outside Russias
territory
The Lower House
The Philippines United States of America United Kingdom Germany France Russia
1. Name House ofRepresentatives
House of Representatives House of Commons Bundestag Assemble nationale
(National Assembly)
Gosudarstvennaya
Duma(State Duma
2. Means ofElection /
Selection of its
Members
Direct vote Direct vote The Queen selects from
persons recommended by
the House of Lords
Appointments
Commission
Direct vote Indirect universal
election
Direct vote
3. Qualificationsa. Citizenship A natural-born citizen of
the Philippines
A US citizen for at least 7
years
Citizens of the UnitedKingdom, Ireland or
N/A A French national A Russian citizen
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b. Agec. Residency
d. Others
any Commonwealth
nation
Aged 25 and above onthe day of the election
Aged 25 and above Aged 18 and above Aged 18 and above Aged 23 and above Aged 21 and aboveA resident of the district
he wants to represent for
at least 1 year prior to
election day
A resident of the state ofthe districthe intends torepresent
None N/A None
Literate Registered voter in
the district he intendsto represent
None Not a subject of theBankruptcy
Restrictions Order (in
England and Wales),
not adjudged
bankrupt (in Northern
Ireland), or does not
have a sequestered
estate (in Scotland)
Not serving a prisonterm for high treason
Registered voter Must be in full
possession of civic
rights
-None
4. Term of Officei. Duration of
Term
3 years 2 years Lifetime 4 years 5 years 5 years
ii. Number ofTerms
Allowed
3 Unlimited Lifetime Unlimited Unlimited (?)
b. Powers Pass an articles ofimpeachment
Passage of laws
Impeachment ofofficials
Debating and passingof laws
Venue
Passes laws along withthe Bundesrat
Assessing andamending the
Bringing chargesagainst the Presi
of the Russian
Federation for
his impeachmen
Approves bills, toforwarded to the
Federal Assembl
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Election of thepresident in case of
a tie
Confirmation of anappointment to the
vice-Presidency by
the President
Designation of theVice-President as
acting President
Overriding aPresidential veto
Elect the President incase of an Electoral
College tie
Initiate revenue bills Scrutinizing
government policies
Enabling theGovernment to raise
taxes
government's
legislative program
Enacts federallegislation
Elects the Chancellor
Exercises oversight ofthe executive branch
on issues of both
substantive policy and
routine administration
Scrutinizinggovernment policies
later
Consent to theappointment of
Russian PrimeMinister
Hearing annualreports from the
Government of t
Russian Federati
on the results of
work, including o
issues raised by t
State Duma
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Veto legislationpassed by the
Bundestag
Overthrow thegovernment (of the
Prime Minister and
other ministers) by
a vote of no-
confidence
Decides the issuconfidence in th
Government of t
Russian Federati
Appointment andismissal of the
Chairman of
the Central Bank
Russia
Appointment andismissal of the
Chairman and ha
the auditors of t
Accounts Chamb
Appointment andismissal of the
Commissioner fo
Human Rights, w
shall act accordin
to federal
constitutional law
Announcement oamnesty
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Philippine Legislative Process
Legislation can start in either House. First, a member of Congress must introduce the bill. The bill undergoes First Reading, referred to one of the
Committees (in the house where the bill was files), undergoes Second and Third Reading. When the bill passes the Third Reading, it goes to the
other House of Congress, where it will undergo the same procedure. There may be amendments to the original bill; these must be
reconsidered until the approval of both houses of Congress is gained. The bill then goes to the President for approval / veto.
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American Legislative Process
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British Legislative Process
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German Legislative Process
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French Legislative Process
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1. Statute legislation may be proposed by the government (council of ministers), or by members of Parliament. In the first case, it is a projet de loi; in thelatter case, aproposition de loi.
Allprojets de loi must undergo compulsory advisory review by the Conseil d'tatbefore being submitted to parliament. Since 2009, the billsubmitted to Parliament must also come with a study of the possible impact of the law: other possible options, interactions with European
law, economical, social, financial and environmental consequences.
Propositions de loicannot increase the financial load of the state without providing for funding.2. Projets de loi start in the house of the government's choice (except in some narrow cases).
Propositions de loi start in the house where they originated. After the house has amended and voted on the text, it is sent to the other house, which can also
amend it. If the houses do not choose to adopt the text in identical terms, it is sent before a commission made of equal numbers of members of both
houses, which tries to harmonize the text. If it does not manage to do so, the National Assembly can vote the text and have the final say on it (except for
laws related to the organization of the Senate).
3. The law is then sent to the President of France for signature. At this point, the President of France, the speaker of either house or a delegation of 60deputies or 60 senators can ask for the text to undergo constitutional review before being put into force; it is then sent before the Constitutional Council.
The President can also, only once per law and with the countersigning of the Prime minister, send the law back to parliament for another review. Otherwise,
the President must sign the law. After being countersigned by the Prime minister and the concerned ministers,it is then sent to the Journal Officiel for
publication.
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Russian Legislative Process
The legislative process in Russia includes three hearings in the State Duma, then approvals by the Council of the Federation and the President.
1. Laws adopted by the State Duma are passed to the Council of the Federation for review. A federal law is considered passed by theCouncil of the Federation if more than half of its deputies vote for it or if within 14 days it has not been considered.
In the event the State Duma disagrees with the decision of the Federation Council, a federal law is considered adopted if, in the
second voting, at least two-thirds of the total number of deputies to the State Duma vote for it.
2. Then, however, laws must be considered by the Council of the Federation. These are laws that:a. deal with the issues of the federal budget, federal taxes and duties, financial, monetary, credit and customs regulations and money
emission;
b. ratification and denunciation of the international treaties; and,c. the status and protection of the state border and issues of war and peace.
3. The adopted federal law is sent to the president. If the president rejects a federal law the State Duma and the Federation Council againconsider the law. If, during the second hearings, the federal law is approved in its earlier draft by a majority of not less than two-thirds of
the total number of deputies of the Council of the Federation and the State Duma, it must be signed by the president.
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The Judicial Branch
Judges and Justices
The Philippines United States of America United Kingdom Germany France Russia
1.
Nature ofAppointment Appointed by thePresident with the
consent of the
Commission on
Appointments in the
Congress.
Appointed by thePresident and confirmed
by the Senate
Judges of the SupremeCourt are appointed by
The Queen by the issue
of letters patent, on the
advice of the Prime
Minister, to whom a name
is recommended by a
special selection
commission.
Nominees for theFederal Constitutional
Court
(Bundesverfassungsgericht) are elected bythe Bundestag and
Bundesrat
Candidates for theFederal Administrative
Court are selected by
an electoral
committee and
appointed by the
Federal President
Candidates for theFederal Court of
Justice are elected by
an electoral
committee selected by
the Bundestag
Appointed by thePresident and approved
by the Conseil Suprieurde la Magistrature (HighCouncil of the Judiciary)
Appointed by thePresident and appro
by the Federal Coun
2. Qualificationsa.Citizenship A natural-born citizen of
the Philippines
N/A N/A A German citizen A French national A Russian citizen
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b.Age For Supreme Courtjustices, at least forty (40)
years of age.
For RTC Judges, at least35 years of age
For MTC judges, atleast 30 years of age
N/A
N/A N/A Aged 40 and abofor would-be
Constitutional
Judges
Aged 35 and abofor applicants in
Supreme Arbitra
Court and SupreCourt
c.Practice ofLaw
For Supreme Courtjustices, at least 15 years
For RTC judges, at least10 years
For MTC judges, atleast 5 years
Justices of theSupreme Court are
usually appointed
from those holding
high judicial office
either in the English
Court of Appeal or in
the equivalent courts
in Scotland or
Northern Ireland. Must
have held a Supreme
Court qualification for
at least 15 years
Lord Justices ofAppeal must have a
seven year high Court
Qualification or be an
existing High Court
Judge
High Court Judgesmust have had the
right to practice in the
High Court for at least
seven years or been aCircuit Judge for at
None Applicants for thConstitutional Co
must be a lawye
at least 15 years
Applicants for thSupreme Arbitra
Court and Supre
Court must be a
lawyer for at leas
years
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d.Others
least two years
Circuit Judges musteither have had rights
of audience in the
Crown or County
Court for at least
seven years or have
been a Recorder Recorder must have
practised as a barrister
for at least seven years
District Judges musthave a five year
general qualification
as either a barrister or
a solicitor.
To become aSupreme Court
justice, the applicant
must be a person of
proven competence,integrity, probity and
independence.
Each nomineeundergoes
confirmation hearings
conducted by the
Senate Judiciary
Committee
No specificrequirements havebeen set by the
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Constitution, but
members of the
Congress and the
Department of Justice
have set their own
informal criteria Makes clear that hewill at all times uphold
the free democratic
order within the
meaning of the
Grundgesetz (Basic
Law)
Mastery of requisitesocial skills
Law graduates musttake the First State
Examination
Successful applicantsundergo a state-
sponsored 30-monthtraining
Students take theSecond State
Examination. Rankings
in this examination will
serve as the basis for
students applications
in a particular Land
Civil servants withappropriate
qualifications andProfessors are also
qualified
Law practitioners forat least 8 years may
take a competitive
examination and
short training
organized by the
Ecole Nationale de laMagistrature (JudicialTraining School)
Legal Education
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3. Term of Officea. Limitation They hold office
during good
behavior until they
reach the age of
seventy (70) years or
become
incapacitated to
discharge the duties
of their office.
They serve no fixedterm they serve until
their death, retirement,
or conviction by the
Senate and they can
only be removed
through impeachment
by the House of
Representatives and
conviction in the
Senate.
Judges may beappointed on
probation, for a
specified term, or for
life, depending on the
provisions of federal
and state law
All judges serve life, except for
members of the
Constitutional Co
who serve for 12
year terms
The Courts
The Philippines United States of America United Kingdom Germany France Russia
1. Supreme Court Supreme Court of thePhilippines
The highest court inthe land and court
of final appeal
Supreme Court of the
United States
Highest court in theland and court of final
appeal
The Supreme Court
Highest court in theland and court of final
appeal
NOTE: These courts are
the five Federal Courts
set forth in the German
Basic Law
Bundesgerichtshof
(Federal Court of
Justice)
Court of last resort inall matters of criminal
and private law
Cour de cassation
(Court of Cassation)
Court of finalappeal for civil and
criminal matters
The Supreme Court
the Russian Federat
Court of lastresort in Russian
administrative
law, civil
law and criminal
cases
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Deals with casesinvolving the
constitutionality of a
treaty, international
or executive
agreement, or law,
which shall be heard
by the Supreme
Court en banc, and
all other cases which
under the rules of
court.
Review, revise,reverse, modify, or
affirm on appeal or
certiorari as the law
or the Rules of court
may provide, final
judgments andorders of lower
courts
Deals with matterspertaining to the
federal government,
disputes between
states, and
interpretation of the
United States
Constitution.
Can declare legislationor executive action
made at any level of
the government as
unconstitutional,
nullifying the law andcreating precedent for
future law and
decisions.
Concentrates on casesof the greatest public
and constitutional
importance
Hears appeals onarguable points of law
of general public
importance
Bundesverfassungsgerich
t(Federal Constitutional
Court)
Hears cases ofconstitutional
violation filed before
the Court
Violations of electionlaws may be brought
before the court by
political institution or
any involved voter.
Bundesfinanzhof
(Federal Fiscal Court)
Predominantlyadjudicates in legal
remedy procedures
upon the legality of
assessments of taxes
and duties,
furthermore about
child allowance,
investment allowanceand certain concerns
regarding the
Challenging ofindividual acts of
Federal
Assemblyanddecrees of
thePresident ofRussiaand
theGovernmentRussia
Challenging ofdelegated legisla
of governmenta
agencies
Termination ofpolitical parties a
all-RussianNGOChallenging of
actions ofCentraElectoral
Commission of
Russiawhen
organizingpresi
ial elections,Stat
Dumaelections
orreferendum
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professional law for
tax consultants.
Bundessozialgericht
(Federal Social Court)
Secure legal uni-formity and thedevelopment of the
law Exercise jurisdiction
over statutory
insurance systems
which comprise
pension, accident,
health,
unemployment, and
long-term care insur-
ance; state
compensation for
damage to health,
namely compensation
for members of the
armed forces and the
victims of violence;
child raising
allowance, matters
involving welfare
benefits
Bundesarbeitsgericht
(Federal Labor Court) Labour Courts do not
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only resolve disputes
between employees
and employers over
employment rights,
but also similar
disputes arising from
contractual
relationships of
development aid
workers, volunteers
and disabled persons
working in sheltered
workshops.
2. AppellateCourts
Court of Appeals
Reviews thedecisions and orders
of the Regional Trial
Courts nationwide,
Court of TaxAppeals, as well as
the awards,
judgments, final
orders or resolutions
of, or authorized by
21 Quasi-Judicial
Agencies
Court of Appeals
Decides appeals fromthe district courtswithin its federal
judicial circuit, and in
some instances fromother designated
federal courts
and administrative
agencies
Serves as the finalarbiter on most federal
cases.
Court of Appeal
Composed of two
divisions:
The Civil Division,which hears
appeals from: The three
divisions of
the High
Court
(Chancery,
Queen's
Bench and
Family
Division)
From theCounty Courts
acrossEngland and
Wales,
NOTE: The Supreme
Courts act as appellate
courts at the same time
Cour d'appel
The Court is dividedinto a number of
divisions or courts:
social security,
business, generalcivil, and criminal.
This is the only
court that requires
the intervention of
a solicitor or case
attorney (avou) toprepare and
manage your case
and to act as an
intermediary
between the
barrister and theappellant or
appellee.
NOTE: The Supreme
Court act as an appe
court at the same tim
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From certainTribunals such
as the
Employment
Appeal
Tribunal, the
Immigration
Appeal
Tribunal, the
Lands Tribunal
and the Social
Security
Commissioner
s.
The CriminalDivision, which
hears appeals from
the Crown Court.
3. ConstitutionalCourt
The Supreme Court decides on matters related to the
Constitution
Contrary to popular belief,
no British Constitution
exists not because it is
unwritten but because it is
composed of several
documents, statutes, court
judgments and treatises.
Bundesverfassungsgerich
t(Federal Constitutional
Court)
Hears cases ofconstitutional
violation filed before
the Court
Violations of electionlaws may be brought
before the court bypolitical institution or
any involved voter.
Counseil
Constitutionnel
(Constitutional
Council)
Rule on whetherproposed statutes
conform with the
Constitution, after
they have been
voted by Parliamentand before they are
signed into law by
Constitutional Cou
the Russian Federat
Protect theConstitution (in
Russian
constitutional law
this function is
known as
"constitutional
control" or"constitutional
supervision") and
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the President of the
Republic
Individual citizensparty to a trial or
lawsuit can also ask
for the Council to
review whether the
law applied in the
case is
constitutional.
deal with a few k
of disputes wher
has original
jurisdiction
4. Economic Court Court of Tax Appeals Decides on cases
related to the
National Internal
Revenue Code and
Tariff and Customs
Code and those
involving local and
real property taxes
N/A N/A Bundesfinanzhof
(Federal Fiscal Court)
Predominantlyadjudicates in legal
remedy procedures
upon the legality of
assessments of taxes
and duties,
furthermore about
child allowance,
investment allowanceand certain concerns
regarding the
professional law for
tax consultants.
Cours de Comptes
(Court of Auditors)
Conducts financialand
legislative audits of
most public
institutions and
some private
institutions,
including the
centralGovernment,
national public
corporations, social
security agencies,
and public services
Supreme Arbitratio
(Commercial) Cour
Superior judicialbody for the
resolution of
economic disput
and other cases
examined by
arbitration court
exercises judicia
supervision overtheir activity in th
procedural form
envisaged by law
and issues
explanations on
matters of judici
practice
5. Labor Court N/A N/A Employment Tribunal Hears cases related to
unfair dismissal,
redundancy
paymentsandemployment
Bundesarbeitsgericht
(Federal Labor Court)
Labour Courts do notonly resolve disputes
between employeesand employers over
employment rights,
Conseil de
Prud'hommes
(Industrial Tribunal)
First-instancelabour court whoseunique feature is its
strictly joint
N/A
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discrimination but also similar
disputes arising from
contractual
relationships of
development aid
workers, volunteers
and disabled persons
working in sheltered
workshops.
composition, with
half of its members
(judges) elected by
employees and half
by employers.
It has exclusivecompetence for
dealing with
individual disputes
arising from the
contract of
employment.
6. Social Court N/A Bundessozialgericht(Federal Social Court)
Secure legal uni-formity and the
development of the
law Exercise jurisdiction
over statutory
insurance systemswhich comprise
pension, accident,
health,
unemployment, and
long-term care insur-
ance; state
compensation for
damage to health,
namely compensation
for members of the
armed forces and the
victims of violence;child raising
allowance, matters
N/A
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involving welfare
benefits
7. Anti-CorruptionCourt
Sandiganbayan
Exercises jurisdictionover criminal and
civil cases involving
graft and corrupt
practices and such
other offenses
committed by public
officers and
employees, including
those in
government-owned
or controlled
corporations, in
relation to their
office as may be
determined by law.
N/A
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nal_Court_of_Germanyhttp://en.wikipedia.org/wiki/Federal_Constitutional_Court_of_Germanyhttp://en.wikipedia.org/wiki/Federation_Council_of_Russiahttp://en.wikipedia.org/wiki/Federation_Council_of_Russiahttp://en.wikipedia.org/wiki/Federation_Council_of_Russiahttp://en.wikipedia.org/wiki/French_Senatehttp://en.wikipedia.org/wiki/French_Senatehttp://en.wikipedia.org/wiki/French_Senatehttp://en.wikipedia.org/wiki/French_Senatehttp://en.wikipedia.org/wiki/Federation_Council_of_Russiahttp://en.wikipedia.org/wiki/Federal_Constitutional_Court_of_Germanyhttp://en.wikipedia.org/wiki/Federal_Administrative_Court_of_Germanyhttp://en.wikipedia.org/wiki/Departments_of_the_United_Kingdom_Governmenthttp://en.wikipedia.org/wiki/Court_of_Audit_of_Francehttp://en.wikipedia.org/wiki/Constitutional_Council_of_Francehttp://en.wikipedia.org/wiki/Cabinet_of_Francehttp://en.wikipedia.org/wiki/British_Prime_Minister#Powers_and_constraintshttp://www.uscourts.gov/Common/FAQS.aspxhttp://www.unhcr.org/refworld/publisher/GBR_CA_CIV.htmlhttp://www.unc.edu/depts/europe/francophone/principles_en.pdfhttp://www.supremecourt.gov.uk/about/role-of-the-supreme-court.htmlhttp://www.state.gov/r/pa/ei/bgn/3842.htm#govhttp://www.senate.gov.ph/about/legpro.asphttp://www.russiavotes.org/duma/duma_electoral_system.phphttp://www.russianlawonline.com/content/legislative-processhttp://www.rogerdarlington.me.uk/Frenchpoliticalsystem.htmlhttp://www.parliament.uk/documents/lords-information-office/holwork.pdfhttp://www.parliament.uk/documents/lords-information-office/hoflbpmembership.pdfhttp://www.parliament.uk/business/commons/what-the-commons-does/http://www.parliament.uk/about/mps-and-lords/about-lords/what-the-lords-do/http://www.parliament.uk/about/mps-and-lords/about-lords/lords-appointment/http://www.llrx.com/features/russia.htmhttp://www.law.cam.ac.uk/faculty-resources/10000865.dochttp://www.justice.gov.uk/courts/rcj-rolls-building/court-of-appealhttp://cta.judiciary.gov.ph/http://www.iuscomp.org/gla/statutes/DRiG.pdfhttp://www.infoplease.com/world/leaders/france.htmlhttp://www.helpwithlawexams.co.uk/thejudiciary.htmlhttp://www.eurofound.europa.eu/emire/FRANCE/INDUSTRIALTRIBUNAL-FR.htm7/31/2019 Comparative Analysis of the Governments of PH, US, Germany, FR, RU, and UK
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http://en.wikipedia.org/wiki/Government_of_France#Legislation_adoption_procedureshttp://en.wikipedia.org/wiki/Government_of_France#Legislation_adoption_procedureshttp://en.wikipedia.org/wiki/Government_of_France#Legislation_adoption_procedureshttp://en.wikipedia.org/wiki/Judiciary_of_Francehttp://en.wikipedia.org/wiki/Judiciary_of_Francehttp://en.wikipedia.org/wiki/Judiciary_of_Francehttp://en.wikipedia.org/wiki/Judiciary_of_France#Court_of_Appealhttp://en.wikipedia.org/wiki/Judiciary_of_France#Court_of_Appealhttp://en.wikipedia.org/wiki/Judiciary_of_France#Court_of_Appealhttp://en.wikipedia.org/wiki/Justice_of_the_Supreme_Court_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Justice_of_the_Supreme_Court_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Justice_of_the_Supreme_Court_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/List_of_political_term_limits#Europehttp://en.wikipedia.org/wiki/List_of_political_term_limits#Europehttp://en.wikipedia.org/wiki/List_of_political_term_limits#Europehttp://en.wikipedia.org/wiki/President_of_Francehttp://en.wikipedia.org/wiki/President_of_Francehttp://en.wikipedia.org/wiki/President_of_Francehttp://en.wikipedia.org/wiki/President_of_Germany#Duties_and_functionshttp://en.wikipedia.org/wiki/President_of_Germany#Duties_and_functionshttp://en.wikipedia.org/wiki/President_of_Germany#Duties_and_functionshttp://en.wikipedia.org/wiki/Prime_Minister_of_Francehttp://en.wikipedia.org/wiki/Prime_Minister_of_Francehttp://en.wikipedia.org/wiki/Prime_Minister_of_Francehttp://en.wikipedia.org/wiki/Prime_Minister_of_Russiahttp://en.wikipedia.org/wiki/Prime_Minister_of_Russiahttp://en.wikipedia.org/wiki/Prime_Minister_of_Russiahttp://en.wikipedia.org/wiki/Queen_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Queen_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Queen_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Russian_supreme_courthttp://en.wikipedia.org/wiki/Russian_supreme_courthttp://en.wikipedia.org/wiki/Russian_supreme_courthttp://en.wikipedia.org/wiki/State_Dumahttp://en.wikipedia.org/wiki/State_Dumahttp://en.wikipedia.org/wiki/State_Dumahttp://en.wikipedia.org/wiki/Succession_to_the_British_thronehttp://en.wikipedia.org/wiki/Succession_to_the_British_thronehttp://en.wikipedia.org/wiki/Succession_to_the_British_thronehttp://en.wikiversity.org/wiki/File:French_government.pnghttp://en.wikiversity.org/wiki/File:French_government.pnghttp://en.wikiversity.org/wiki/File:French_government.pnghttp://uk.answers.yahoo.com/question/index?qid=20080227033714AAgd27Phttp://uk.answers.yahoo.com/question/index?qid=20080227033714AAgd27Phttp://uk.answers.yahoo.com/question/index?qid=20080227033714AAgd27Phttp://uk.answers.yahoo.com/question/index?qid=20080227033714AAgd27Phttp://en.wikiversity.org/wiki/File:French_government.pnghttp://en.wikipedia.org/wiki/Succession_to_the_British_thronehttp://en.wikipedia.org/wiki/State_Dumahttp://en.wikipedia.org/wiki/Russian_supreme_courthttp://en.wikipedia.org/wiki/Queen_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Prime_Minister_of_Russiahttp://en.wikipedia.org/wiki/Prime_Minister_of_Francehttp://en.wikipedia.org/wiki/President_of_Germany#Duties_and_functionshttp://en.wikipedia.org/wiki/President_of_Francehttp://en.wikipedia.org/wiki/List_of_political_term_limits#Europehttp://en.wikipedia.org/wiki/Justice_of_the_Supreme_Court_of_the_United_Kingdomhttp://en.wikipedia.org/wiki/Judiciary_of_France#Court_of_Appealhttp://en.wikipedia.org/wiki/Judiciary_of_Francehttp://en.wikipedia.org/wiki/Government_of_France#Legislation_adoption_procedures