Thus, to create a balance between the decision of the victim of the harassment and the mandatory aspect of reporting said occurrence by the authorities, the Commission offers for consideration the inclusion of the following in its Section 4, to wiU "Dtte consideration should be giuen to the desire of the uictim in the filing of a complaint." S. Section 6 of the proposed legislation seems to cover only those cases where the victim can demonstrate "their express resistance but do not include those resistances that were made impliedlywhich can also reflect the victims lack of consent. The Commission proposes that the language and intent of the "no means no" principle as stated in its Section 6 be improved to protect the human rights of victims of such abuse and harassment through inclusion of this school of thought that the lack of protest or resistance does not mean consent and that silence also do not mean consent. No means no does not always have to be verbally uttered especially those cases where the intended victim lacks the ability to speak by reason of any psychological or medical reasons. Lack of consent can be demonstrated not only through express physical or verbal resistance but also through behavioral resistance amounting to rts implied protest such as flight from the scene or place of harassment. Further, there are instances when the supposed victim would initially give consent to the sexual advances of another, either the victim would freeze out of fear, or just plain approval, but would eventually resist to further advances. In this particular scenario, the provision on the no mecns no shall provide that the lack of consent can be manifested by the victim at any stage of the act constituting harassment and it shall not matter whether the victim initially gave his/her consent. Thus, the Commission respectfully recommends the following to be included in its Section 6; Sec. 6. "No meens No" Principle. xxx Further, in cases ushere the uicttm either lacks ability to speak, by reason of any psychological or medical condition, or unable to resist before and/or during harassment, lack of consent can be manifested through the uicttms behauior before, during, or after the occurrence of the s.ct or acts complained of constituting harassment. to Apprehend Gender-based Street Harassment Perpetrators to Light and Medium Offenses. 4. Authority We recommend that enforeers of the MMDA undergo gender sensitivity training prior to auttfc;:izing them to receive and act on complaints of sexual harassment to ensure that victims do not face further abuse or harassment. ?h{ 4