In Comunale v. Traders & General Ins. Co. (1958) 50 Cal.2d 654, a first party bad faith action, the court made its oft-quoted declaration: "There is an implied covenant of good faith and fair dealing in every contract that neither party will do anything which will injure the right of the other to receive the benefits of the agreement. . . . This principle is applicable to policies of insurance." (Comunale, 50 Cal.2d at page 658.) The court further held as a general rule the limitations period applicable to such a cause of action was the four year period for an action based on a written contract. Because some bad faith actions have traditionally been treated as torts, the court ruled "where a case sounds both in contract and tort the plaintiff will ordinarily have freedom of election between an action of tort and one of contract." (Comunale, 50 Cal.2d at page 663.)