Case Digest (G.R. No. 191667) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Land Bank of the Philippines v. Eduardo M. Cacayuran, decided on April 17, 2013 under the 1987 Constitution, the Municipality of Agoo, La Union sought loans from Land Bank to implement a three-phase Redevelopment Plan for the historic Agoo Public Plaza. In April and October 2005, the Sangguniang Bayan (SB) passed Resolutions Nos. 68-2005 and 139-2005 authorizing Mayor Eufranio Eriguel to obtain a ₱4,000,000 loan (First Loan), secured by a 2,323.75 sqm portion of the Plaza Lot and an assignment of part of the Municipality’s internal revenue allotment (IRA) and future project income. In March and September 2006, the SB enacted Resolutions Nos. 58-2006 and 128-2006 to authorize a further ₱28,000,000 loan (Second Loan) under the same securities. Opposed by resident‐taxpayer Eduardo Cacayuran, who led a signature campaign and filed a taxpayer’s complaint against the SB members, the Mayor, Vice Mayor Antonio Eslao, and Land Bank, the case was brought to the Regional Trial Court (RT Case Digest (G.R. No. 191667) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Redevelopment Plan and First Loan
- From 2005 to 2006, the Sangguniang Bayan (SB) of Agoo passed resolutions to implement a multi-phased Redevelopment Plan for Agoo Public Plaza, including Imelda Garden and Rizal Monument.
- SB Resolution No. 68-2005 (April 19, 2005), ratified by Resolution No. 139-2005 (October 4, 2005), authorized Mayor Eriguel to obtain a ₱4,000,000 loan from Land Bank, to mortgage the 2,323.75 sqm Plaza Lot as collateral, and to assign a portion of the Municipality’s IRA and project income.
- On November 21, 2005, Land Bank granted the First Loan; proceeds funded construction of ten kiosks in Imelda Garden, which were subsequently rented out.
- Phase II and Second Loan
- SB Resolution No. 58-2006 (March 7, 2006), ratified by Resolution No. 128-2006 (September 5, 2006), approved construction of a commercial center on the Plaza Lot, authorized a second loan under the same securities.
- On October 20, 2006, Land Bank granted the Second Loan of ₱28,000,000; construction completed, later known as Agoo People’s Center (APC).
- Public Opposition and Taxpayer’s Complaint
- Resident Eduardo Cacayuran led a signature campaign and filed a Manifesto and December 8, 2006 letter requesting certified copies of resolutions and loan agreements, alleging irregularity and desecration of public park.
- Unable to obtain documents, Cacayuran, invoking taxpayer status, filed a Complaint (December 2006) against Land Bank and SB members, assailing the validity of the Subject Loans and collateralization of public-dominion property.
- Judicial Proceedings
- RTC Decision (April 10, 2007): declared the Subject Loans null and void, held SB resolutions ultra vires, and ruled the Plaza Lot cannot be mortgaged.
- CA Decision (March 26, 2010): affirmed with modification (exempting Vice Mayor from personal liability), upheld Cacayuran’s standing, invalidity of resolutions, public-dominion status of Plaza Lot, and ultra vires nature of the loans.
- Land Bank filed this Petition for Review on Certiorari before the Supreme Court.
Issues:
- Whether Eduardo Cacayuran, as a taxpayer, has standing to challenge the Subject Loans.
- Whether the SB Resolutions authorizing the loans were validly passed under the Local Government Code.
- Whether the Subject Loans are ultra vires and thus void.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)