(Game here is Parasite Eve 2)
It didn't happen in every game but often enough that it's noticeable. They're usually not shot as straight-up titillation, instead going for a tasteful nudity kind of thing and intended to fulfill some kind of storytelling or characterisation purpose
"You see, you gotta show them being vulnerable. They may be badass, but they're still girls, after all"
-90s game director, probably
Oh my fucking god, this is so hot, uhhffddt, aaaaaaa, its all over the place!!!! - says kojimbo after seeing Taraxacum officinale