Does a rolling limitation period apply to a claim for periodic payments?

In Richards v. Sun Life Assurance Company of Canada, 2016 ONSC 5492, [2016] I.L.R. I-5911, at para. 26, Bale J. distinguished between cases where the plaintiff is entitled to periodic payments and cases where the plaintiff’s entitlement to periodic payment is in issue: A rolling limitation period may apply to claims for periodic payments, in cases where the issue is whether certain payments to which the plaintiff is entitled have been made (e.g. payments of rent), as opposed to cases where the issue is whether the plaintiff was entitled to the periodic payments in the first place. In the former type of case, the material facts will have arisen on a periodic basis, and it will not be unfair to require a defendant to litigate those facts during the applicable limitation period following the date upon which an individual payment became due. However, in the latter type of case, the material facts will have arisen at the time that the plaintiff alleges he or she first became entitled to periodic payments, and it would be unfair to require the defendant to litigate those facts, for a potentially unlimited period of time.