Complaints of rape cases have increased, around 16 (sixteen) to 20 (twenty) percent annually based on the records of Komnas Perempuan in 2020. Of these complaints, only 10 (ten) percent have entered the legal process, and very few have been resolved until court decision process. The investigating apparatus still considers the element of coercion to be physically proven by using a visum et repertum. Physical evidence is very easy for a recent rape case, but it can be an obstacle for victims who do not immediately make a complaint, where the physical evidence is no longer visible. This is because the victim is still experiencing severe psychological trauma with myths and stigma against victims of rape, as the source of the rape. Even in the legal process, the question always arises, whether the victim fought back, and if there is no resistance then it will be difficult to physically prove it, even the assumption that the victim agreed to the rape. In a situation of fear, there is a motor reaction which results in a psychological result that makes the victim unable to resist, this is called tonic immobility. As a result, the legal process becomes difficult for rape cases or the legal process stops because there is no evidence of coercion being fulfilled. The victim experiences loss or blaming the victim. Even though in Article 285 of the Criminal Code, the criminal act of rape is an ordinary offense, which means that a criminal act can be prosecuted without the need for a complaint from the victim, in reality the legal process really requires the active role of the victim.