How so? It's in the oil bath the whole time....what's the difference between it being towed and driving?
When driving in fourth gear both shafts are turning at the same speed, and on the open road doing long distances you would usually be cruising in fourth gear most of the time. When in neutral and being towed the first motion shaft is stationary and the main shaft driven by the diff is spinning merrily away.Get the picture 
Rolf is correct here with his advice.
Although the shafts and bearings are in an Oil Bath, the Oil is stone cold and has no way of heating up.
Also, when flat towed in Neutral, the 3rd motion shaft spins over quite fast, while the 1st motion shaft is stationary, between there two shafts is a small bearing, which is not rated for continuous duty like this, the end result usually being this bearing and the shafts being damaged.
This is a 3rd Motion Shaft I took from a Gearbox that was damaged from being flat towed;-
