The case involves an arbitration dispute between Dalian Professional Football Club and Ricardo Filipe Rodrigues Matos, a Portuguese football coach, along with FIFA, concerning the termination of the coach's employment contract. The Court of Arbitration for Sport (CAS) issued an award on 17 September 2021, addressing several key legal issues. The dispute arose when the club terminated the coach's contract on December 26, 2018, without providing a reason, despite an automatic extension clause triggered by the team's 11th-place finish in the Chinese Super League (CSL), which extended the contract until December 31, 2020. The coach claimed the termination was without just cause and sought compensation for the remaining contract value, unpaid bonuses, and tax compliance certificates. The club countered by challenging FIFA's jurisdiction, arguing the termination was lawful and seeking damages from the coach for alleged breaches of contract.
The CAS panel examined multiple issues, including the admissibility of new evidence after written submissions, the validity of the termination, and the enforceability of contractual penalty clauses. The panel ruled that Article R56 of the CAS Code strictly limits post-submission evidence to exceptional circumstances, which were not present in this case. On the termination issue, the panel applied Swiss law, specifically Article 337 of the Swiss Code of Obligations (SCO), which defines "just cause" as circumstances making the continuation of the employment relationship unconscionable. The panel found no material breach by the coach justifying termination, concluding the club acted without just cause.
The panel also addressed the validity of the contract's termination clause, which stipulated differing compensation amounts for the club and coach in case of unilateral termination. The coach argued the clause was unbalanced and lacked reciprocity, but the panel upheld its validity under Swiss law, emphasizing party autonomy and the absence of overall contract imbalance. The panel determined the coach was entitled to compensation for the remaining contract value, adjusted for any post-termination earnings, which the club failed to prove the coach had avoided.
Regarding jurisdiction, the panel confirmed FIFA's competence under Article 22c of the FIFA Regulations on the Status and Transfer of Players (RSTP), rejecting the club's argument that the dispute should have been resolved by the Chinese Football Association Arbitration Committee (CFAAC). The panel found the contractual jurisdictional clause unclear and inoperable, reinforcing FIFA's authority in employment disputes of international dimension.
The panel also ruled on the club's obligation to provide tax certificates, affirming FIFA's limited jurisdiction over tax matters unless contractually grounded. Since the employment contract stipulated net payments after Chinese taxes, the panel upheld the coach's request for tax compliance proof to avoid double taxation.
Finally, the club sought reimbursement of procedural costs from FIFA, but the panel dismissed this request, citing CAS jurisprudence that prohibits reallocating costs from prior proceedings. The panel partially upheld the appeal by adjusting the compensation amount but otherwise affirmed the FIFA Single Judge's decision, mandating payment within 30 days. The case underscores the importance of contractual clarity, procedural adherence, and the balance between party autonomy and fairness in sports-related disputes.