Does the statute of limitations apply when excess rent is offsetted as an affirmative defense to an unlawful detainer action?

Subsequently, in Minelian v. Manzella (1989) 215 Cal.App.3d 457, 263 Cal.Rptr. 597, the same court that decided Nourafchan v. Miner, supra, 169 Cal.App.3d 746, 215 Cal.Rptr. 450, held the above-quoted language from Nourafchan was dictum and "given the equitable nature of such an offset, no statute of limitations applies when excess rent paid is used as an affirmative defense to an unlawful detainer action...." (215 Cal.App.3d at p. 460, 263 Cal.Rptr. 597.)