Philippine Football Federation v. El Barae Jrondi

Moroccan coach El Barae Jrondi signed a two-year contract with the Philippine Football Federation on 12 March 2023, publicly announced 21 March 2023, covering the national team's AFC Asian Cup and 2026 FIFA World Cup qualification cycle. His tenure was brief and difficult: the Philippines lost 2-0 to Kuwait and 4-0 to Jordan in his only matches in charge, and by May 2023 he was no longer head coach. His contract contained a termination clause allowing only the Federation to end it unilaterally, capping the compensation payable to Jrondi at a fixed sum regardless of how much of the contract remained. On the date of termination, Jrondi had nearly two years left on a contract worth QAR 600,000 — but the clause limited his compensation to just QAR 54,000, under 10% of the contract's residual value.

FIFA's Players' Status Chamber ruled the termination lacked just cause. On appeal to CAS, the PFF tried something procedurally unusual: it produced, for the first time at the CAS stage, evidence that Jrondi had since taken up new coaching positions in Morocco — specifically with club AS FAR — and Saudi Arabia, evidence it had not put before the PSC.

The Sole Arbitrator, Oliver Jaberg, had to decide, as a threshold matter, whether to even admit evidence that could have been raised earlier but wasn't. He chose to admit it, treating Jrondi's new employment as an exceptional circumstance worth considering given how directly it bore on the actual financial loss he'd suffered. On the underlying merits, though, admitting the late evidence didn't rescue the PFF's case: the Sole Arbitrator found the termination clause itself abusive and a violation of the principle of contractual stability (pacta sunt servanda), since it let the Federation alone decide to terminate while capping Jrondi's compensation at a fraction of what the remaining contract was actually worth — a one-sided bargain that could not stand regardless of whatever underlying reason the PFF gave for the termination. Jrondi's own testimony, corroborated by a witness identified as Mr Nierras, was found credible and consistent with the documentary record.

Decided 26 September 2025. Where the late evidence did matter was on the remedy: because Jrondi was now earning income from his new Moroccan and Saudi positions, the Sole Arbitrator reduced his compensation to reflect it — the same mitigation principle that runs through several of the employment cases in our library, here operating specifically to lower an award rather than to determine liability in the first place.