G.R. No. 241034 - Manila Hotel Corp. vs. Office of the Director, Bureau of Legal Affairs, Intellectual Property Office of the Philippines

The Municipality of Agoo, La Union (Municipality) entered into two loan agreements (Subject Loans) with the Land Bank of the Philippines (LBP) to finance the redevelopment of the Agoo Public Plaza (Public Plaza).
The Sangguniang Bayan of the Municipality authorized then-Mayor Eufranio Eriguel to enter into a P4,000,000.00 loan from LBP through Resolutions Nos. 68-2005 and 139-2005, which funded the construction of ten kiosks at the Public Plaza.
Subsequently, through Resolutions Nos. 58-2006 and 128-2006, Mayor Eriguel was authorized to obtain a P28,000,000.00 loan for constructing a commercial center called "Agoo People's Center" within the Public Plaza.
The Municipality used a 2,323.75-square meter lot ("Plaza Lot") at the southeastern portion of the Public Plaza as collateral for the loans.

Eduardo M. Cacayuran (respondent), representing a group of residents, opposed the redevelopment and financing through the Subject Loans, alleging irregularities, illegality, and detriment to public interests.
Cacayuran requested municipal officers to furnish documents regarding the redevelopment but was ignored.
Exercising his right as a taxpayer, Cacayuran filed a complaint against LBP and certain municipal officers (except the Municipality) challenging the validity of the loan agreements and seeking to enjoin the commercialization of the Public Plaza.
Municipal officers moved to dismiss the complaint, which was denied; they subsequently filed answers. LBP contended that Cacayuran lacked cause of action since he was not privy to the loan agreements.

Construction of the Agoo People’s Center was completed during the proceedings.
The Sangguniang Bayan later enacted Municipal Ordinance No. 02-2007 declaring the area where the building stood as patrimonial property of the Municipality.

The Regional Trial Court (RTC), Branch 31 in Agoo, declared the Subject Loans null and void due to irregular approval and ultra vires acts by municipal officers.
The RTC held the Municipality not bound by the loans and held municipal officers personally liable.
It also ruled the Plaza Lot, being public property, could not be used as loan collateral.

LBP and municipal officers appealed; the appeal of municipal officers was dismissed for failure to file a brief.
The CA affirmed the RTC’s decision with modification excluding Vice Mayor Antonio Eslao from personal liability. Key CA holdings included:

Cacayuran had locus standi as a resident and taxpayer.
The approving resolutions were invalid due to non-compliance with the Local Government Code (LGC).
The Plaza Lot could not be used as collateral.
Subject Loans were ultra vires and constituted improper disbursement of public funds.

LBP filed a petition for review before the Supreme Court (SC).
The SC, in its April 17, 2013 Decision, denied LBP’s petition, affirming CA rulings on standing, invalidity of resolutions, and municipal officers’ personal liability.

LBP moved for reconsideration reiterating prior arguments on standing and validity of resolutions.
The Municipality filed a Motion for Leave to Intervene and a Motion for Reconsideration-in-Intervention, asserting it as an indispensable party and real party-in-interest, vital to the case since it was the loan contracting party and owner of the Public Plaza and improvements thereon.
Cacayuran opposed the Municipality's intervention, maintaining the Municipality was not a party since the complaint was only against municipal officers in their personal capacity for ultra vires acts.
LBP supported the Municipality's claim to indispensability.

Whether the Municipality of Agoo, La Union, as contracting party to the Subject Loans and owner of the affected property, is an indispensable party that should have been impleaded in the case.
Consequent to such determination, whether the rulings of the courts below, including the Supreme Court, are void or subject to remand for inclusion of the Municipality as a party.