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

In Minelian v. Manzella, supra, plaintiff landlord appealed from an adverse judgment in an unlawful detainer lawsuit. The court addressed the issue of the applicability of a statute of limitations to the defendant tenant's excess rent defense. In the earlier case of Nourafchan v. Miner, supra, 169 Cal.App.3d 746, 215 Cal.Rptr. 450, the court held that a tenant had "the right to offset the excess rent paid during the three-year statutory period (Code Civ. Proc., 338) within which he could bring an action based on section 1809(a)." (169 Cal.App.3d at pp. 752-753, 215 Cal.Rptr. 450.) The Minelian court reasoned that the affirmative defense for excess rent paid is a setoff in the nature of an equitable defense and as long as the tenant's obligation to pay rent exists, his or her right to claim setoff against the landlord would continue. (215 Cal.App.3d at p. 467, 263 Cal.Rptr. 597.) Thus, no statute of limitations applies when excess rent paid is used as an affirmative defense to an unlawful detainer action.