regional parties can distort matters, leading to more than two parties receiving seats in the national legislature, even if there are only two parties competitive in any single district. The following example seems counter to the law: In the Philippines since 1987, no party has been able to control the House of Representatives; although the party of the president usually has the plurality of seats, it still has to seek coalition partners to command a majority of seats. It may be relevant that the Philippines' governance structure changed repeatedly before 1987 and that the country has many distinct social groups. Also, 80% of the seats in the House of Representatives are elected via FPTP, while the senators are elected via plurality-at-large voting. The average number of candidates in the 2013 House of Representatives elections in every district is only 2.69. There are also cases where the principle appears to have an effect, but weakly: In India, there are 38 political parties represented in the Parliament. Like the UK and Canada, India has a winner-takes-all system. Most of the Indian parties are allied with one of two larger electoral coalitions which makes the Indian system functionally somewhat like a two-party system. In Droit constitutionnel et institutions politiques, Olivier Duhamel argues that these 30+ political parties elected in India and the over 25 percent of voting for parties outside the two main alliances shows that the "law according to which the first-past-the-post system tends to produce duopolies only applies in relatively homogeneous societies with a fairly centralized State. Otherwise, the national party system faces competition from regional subsystems." In Canada, five parties are currently represented in the House of Commons, and the number has averaged between 4 and 5 since 1935. In recent decades, the Liberal Party of Canada, the Conservative Party of Canada, the New Democratic Party, the Bloc Québecois have frequently though not always won official party status. Canada has had more than two registered parties in the House of Commons since 1921, and at only three relatively brief periods in Canadian history have there been only three parties represented (1921–1935, 1958–1962, and 1980–1993). Only two parties (Liberals and Conservatives) have ever formed government, but the Progressive Conservative Party fell to fourth party status in 1993 and the Liberal Party of Canada fell to third party status in 2011. Canada has also had a long pattern of minority governments, which