Which law governs the limitation period for registering a foreign judgment or arbitration award?
In a petition for enforcement decided by the Supreme Court on February 5, 1970, the judgment debtor alleged, as a defense for denying exequatur of a Florida judgment, that the cause of action to recover attorneys’ fees was barred under the Venezuelan statute of limitations (2 years). The Supreme Court disregarded the defense. In this opinion, the Supreme Court held that the right to recover attorneys’ fees derives from the action to enforce the judgment and not from the underlying cause of action. An action to enforce a foreign judgment is subject to the applicable Venezuelan statute of limitations.