The Mirror report that Santa Cruz, 29, is determined to leave in January after becoming frustrated at a lack of first team opportunities at Eastlands.
That has led to an enquiry from Hughes who managed him at Blackburn and also signed him for City in a £17.5m deal in June 2009.
Hughes rates Santa Cruz highly but may have a job in persuading City to allow him to join another Premier League club either on loan or in a cut price move.
Santa Cruz, who this week claimed he is not being given a chance by Roberto Mancini no matter what he does in training, has also set his heart on a move to Spain.
The Paraguayan World Cup star is a target for Espanyol after the Spanish club tried to sign him last summer.
Real Mallorca and Getafe are also likely to be interested and City may now offload as they struggle to keep all of their big names and huge signings happy.