It is not necessary that the demand, request or requirement of a sexual favor be articulated in a categorical oral or written statement. It may be discerned…from the acts of the offender. … It is enough that the respondent’s acts result in creating an intimidating, hostile or offensive environment for the employee.21 Furthermore, it is essential that prosecutors, judges, and justices rule that male coworkers can sexually harass a female co-worker and even male subordinates can sexually harass a female on a higher position because of the reality of gender relations. Thus, not only those in a position of power in the workplace, educational, and training institution sexually harass — vertical type or quid pro quo type of sexual harassment — but also any co-worker and subordinate can sexually harass because of gender relations between men and women, known as horizontal or hostile environment type of sexual harassment, that falls under the use of “influence” under the Anti-Sexual Harassment Act of 1995.22 RECOMMENDATIONS:   RA 7877 should be amended to cover sexual harassment outside of the employment, training and educational environment identifying places such as but not limited to streets, parks, schools, markets, and public transportation. The penalty and fine should also be increased while the prescriptive period should be lengthened. To do away with the varied and regressive interpretation of RA 7877, the requirement of authority, influence, and moral ascendancy should be removed; Workplace, training and education sexual harassment should be defined as “an act, or a series of acts involving any unwelcome sexual advance, request or demand for a sexual favor, or other verbal or physical behavior of a sexual nature, committed in a work-related, training or education related environment.” E. Stalking There is no national law penalizing stalking although there are now local ordinances penalizing stalking such as in Quezon City.23 Some rape and rape-slay cases start with stalking24 stressing the importance of enacting a national law against stalking. RECOMMENDATION:  Enact a national law against stalking ADDITIONAL RECOMMENDATIONS ON GBV:  Train barangay officials, medico-legal, police, prosecutors, and judges on gender-responsive handling of GBV cases and ensure the designation of gender focal points for the police, prosecutors, and judges at every local government unit level; 5