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	GR No. 155639 2009-04-22	JANUARIA A. RIVERA v. UNITED LABORATORIES BRION, J.
Arbiter Caday rejected Rivera's contention that under Article 1155 of the Civil Code, "written extrajudicial demand," like letters, effectively interrupted the running of the three-year prescriptive period. He pointed out that while it is true that Article 1155 of the Civil Code was mentioned in Manuel L. Quezon University Association v. Manuel L. Quezon Educational Institution Inc.,[20] the Court did not categorically state that it superseded Article 291 because the said demand letter amounted to nothing, the cause of action having already prescribed.