Dole Philippines, Inc. v. Maritime Company of the Philippines, G.R. No. L-61352, Feb. 27, 1987

Is Art. 1155 of the Civil Code providing that the prescription of actions is interrupted by the making of an extrajudicial written demand by the creditor applicable also to actions brought under the COGSA?

No, written claims does not toll the running of the one-year prescriptive period under the COGSA. (Dole Philippines, Inc. v. Maritime Company of the Philippines, G.R. No. L-61352, Feb. 27, 1987)