Labour Disputes
Texto da decisão
REF. FPSD-18091
Decision of the
Dispute Resolution Chamber
passed on 20 November 2025
regarding an employment-related dispute concerning the player Michael
Santos Silva Alves
COMPOSITION:
Lívia SILVA KÄGI (Brazil & Switzerland), Deputy Chairwoman
Dana MOHAMED AL-NOAIMI (Qatar), Member
Peter LUKASEK (Slovakia), Member
CLAIMANT:
Michael Santos Silva Alves, Brazil
Represented by Victor de Sordi
RESPONDENT:
Dobrudzha, Bulgaria
pg. 2
REF. FPSD-18091
I. Facts of the case
1.
On 18 June 2024, the Brazilian player, Michael Santos Silva Alves (hereinafter: the Player or
the Claimant), and the Bulgarian club, Dobrudzha (hereinafter: the Club or the Respondent)
entered into an employment contract (hereinafter: the Contract) valid as from its date of
signature until 31 May 2026.
2.
Clause 3 of the annexe to the Contract provided as follows (quoted verbatim):
“3. The football club pays the following additional amounts to the football player:
a. Bonus in the amount of 100 (one hundred) BGN net for each goal scored by the player in
an official match of the club.
b. A bonus in the amount of 100 (one hundred) BGN net for each assist made by the player
in an official match of the club.
c. Bonus in the amount determined according to the Rules for the internal order in the club,
but not less than 600 (six hundred) BGN net, for each victory in an official match of the club
in which the football player took part. Half of each premium is paid to the footballer together
with his monthly salary, with the second half of each premium paid after completion of
competitive season.
d. The club pays footballer BGN 600 from rental price owed by footballer for a leased real
estate in city Varna or Dobrich. THE FOOTBALL PLAYER undertakes to strictly observe lease
agreement, as after expiration term or its premature termination, deposit paid by CLUB must
be returned by lessor or football player IN FULL.
e. When CLUB moves to a professional Football League, FOOTBALL PLAYER receives additional
bonus according to internal regulations Club.”
3.
According to the Club, on 10 December 2024, the parties signed a mutual termination
agreement (hereinafter: the Termination Agreement), which provided as follows (quoted
verbatim):
“On this 10th day of December, 2024, between the football player:
MICHAEL SANTOS SILVA ALVES
(full name of football player)
holder of national passport No. FV 175645, valid until February 8, 2028.
and Professional Football Club (FC) Association Football Club Dobrudzha 1919, Dobrich, this
agreement was signed, whereby the employment contract No. 103 dated 07 August 2024
between the parties is terminated by mutual consent as of December 10, 2024.
pg. 3
REF. FPSD-18091
The financial arrangements between the parties are settled.
The deed is signed in three copies - one copy for the parties to the contract and one copy for
the Sports and Technical Commission at the Bulgarian Football Union.”
4.
According to the Club, between 2 July and 15 November 2024, the following payment
receipts were issued by the Club to the Player, referring to payments made by the former
to the latter(hereinafter: the Payment Receipts):
-
A receipt dated 17 June 2024, confirming a payment of EUR 3,000;
-
a receipt dated 2 July 2024, confirming a payment of BGN 4,000;
-
a receipt dated 1 August 2024, confirming a payment of BGN 7,100;
-
a receipt dated 3 September 2024, confirming a payment of BGN 4,000;
-
a receipt dated 3 October 2024, confirming a payment of BGN 6,000;
-
a receipt dated 2 November 2024, confirming a payment of BGN 6,600;
-
a receipt dated 15 November 2024, confirming a payment of BGN 6,200; and
-
a receipt dated 3 December 2024, confirming a payment of BGN 5,400.
5.
The Player contested the veracity of the Termination Agreement and the Payment Receipts
and argued that his signatures were forged.
6.
On 25 November 2024, a flight was scheduled from Varna (Bulgaria) to Salvador (Brazil) for
Ms. Tamaria Barbosa Souza, Ms. Marielle Barbosa Santos and Ms. Mirela Barbosa Santos.
7.
On 11 December 2024, the Player sent a WhatsApp message to a contact saved as “Avenet
Cristi” requesting the payment of a bonus. This individual replied the Player informing him
that “the President” said the bonus would not be paid.
8.
On 10 January 2025, the Player sent a default notice to the Club requesting: (i) confirmation
of its intentions regarding the continuation of the Contract, (ii) to settle the overdue salaries
in the amount of BGN 7,000 and appearance bonuses in the amount of BGN 3,520, and (iii)
to cover the costs associated with the return flight tickets for his family. The Player granted
the Club 10 days to remedy its default.
9.
On 21 January 2025, the Player sent a further notice to the Club reiterating his requests
and granting five additional days to comply.
pg. 4
REF. FPSD-18091
10. On 25 January 2025, the Player sent a letter to the Club stating that he was not aware of
signing a mutual termination agreement and, considering that the Club failed to pay the
overdue salaries, he terminated the Contract invoking just cause.
11. On 4 February 2025, the Club sent the Player the English version of the Termination
Agreement for him to sign it, but to no avail.
II. Proceedings before FIFA
12. On 4 February 2025, the Player filed the claim at hand before FIFA. A summary of the
parties’ respective positions is detailed below.
a. Claim of the Player
13. In his claim, the Player alleged that the Club failed to comply with its financial obligations.
14. The Player further submitted that he placed the Club on default of payment on 10 January
2025 for the first time, and then, on 21 January 2025, a second notice was reiterated.
15. The Player further submitted that on 27 January 2025, he terminated the Contract with just
cause, invoking art. 14bis of the Regulations on the Status and Transfer of Players
(hereinafter: the Regulations).
16. The Player alleged that every payment was made in cash, with the signing of a payslip that
remained solely with the Club.
17. The Player further contended that, after he suffered an injury on August 2024, he started
to receive only partial payments of his salary.
18. The Player claimed to be entitled to a total outstanding amount of BGN 23,000, as follows:
(i) BGN 14,000 as outstanding salaries from August 2024 to January 2025, (ii) BGN 4,800 as
appearance bonus, and (iii) BGN 4,200 as home allowance from August 2024 to February
2025.
19. The Player’s requests for relief were the following (quoted verbatim):
“In view of the aforementioned, the Claimant respectfully requests to this honorable Chamber
the following relief:
(i) To enforce FIFA’s Football Tribunal jurisdiction as competent to rule on the matter;
(ii) To conclude that the Annex is part of the Employment Agreement;
pg. 5
REF. FPSD-18091
(iii) To confirm that Clause 3, item “c” of the Annex prevails over Clause III.2 of the Employment
Agreement; requesting the Respondent the bring to this case the monthly payslip of the
Respondent, bearing them the burden of proof, according to Article 13, PAR. 6 OF THE
Procedural Rules;
(iv) To rule that the Claimant had just cause to early terminate the employment relationship;
(v) To rule that the Club shall pay to the Player a compensation calculated from the residual
value of the Employment Agreement in the amount of EUR 48,000 (forty-eight thousand Euros)
due to the early termination of the Employment Agreement;
(vi) To additionally include to the Compensation of the Player the amount of BGN 23,000
(twenty-three thousand Levas) as overdue salaries, bonuses and housing allowance.
(vii) To order the Respondent to pay interest on the said amounts of 5% p.a, calculated pro
rata;
(viii) To impose a sporting sanction on the Club pursuant to Article 17, par. 3 of the FIFA RSTP;
(ix) To order the Club to cover all costs of the proceedings and to bear all the legal fees and
costs incurred by the Player in connection with the present matter.”
b. Reply of the Club
20. In its reply, the Club alleged that it regularly paid the Player his salaries, bonuses and home
allowances until they mutually agreed to terminate the Contract on 10 December 2024.
21. The Club further asserted that Player chose to be represented by the football agent Mr.
Elidiano Marques Lima (hereinafter: Mr. Marques) who attended the meeting and translated
the Termination Agreement from Bulgarian to Portuguese during the meeting.
22. In this respect, the Club provided a notarized declaration of Mr. Marques that reads as
follows (quoted verbatim):
“Elidiano Marques Lima, PIN: 8203140203, ID card AA2807656/15.10.2024, Ministry of
Interior
I hereby declare that on 07.12.2024 I was present at a meeting - conversation between the
football player of Professional Football Club Dobrudzha 1919 Michael Santos Silva Alves and
the Sports Technical Director of Dobrudzha 1919 Football Club - Engibar Engibarov and I
interpreted into Portuguese and Bulgarian the conversation between the two parties - football
player and sports director. The football player Michael Santos Silva Alves clearly and firmly
confirmed his desire to terminate his employment contract to the representative of the
football club Engibar Engibarov and agreed to terminate his professional contract with the
pg. 6
REF. FPSD-18091
club as of December 10, 2024. Mr. Engibarov paid the football player all remuneration due
as of December 10, 2024 and the money was handed over in cash with a duly issued receipt.
The parties settled their financial relations and the Termination of employment contract deed
of Michael Santos Silva Alves and PFC Dobrudzha was signed voluntarily and unconditionally
by both parties.”
23. The Club asserted that all amounts were paid to the Player in cash and submitted the
Payment Receipts allegedly signed by the Player. The Club further submitted that it can be
seen from the bank statements provided by the Player that those amounts were deposited
by the Player himself and not by the Club.
24. The Club further argued that, in accordance with the Contract, the Player was entitled to
receive a total amount of BGN 40,935 broken down as follows: (i) BGN 34,335 as salaries,
(ii) BGN 2,400 corresponding as bonuses, and (iii) BGN 4,200 corresponding to home
allowances.
25. The Club contended that it ended up paying the Player a total amount of BGN 45,300, i.e.,
exceeding the amount due.
26. The Club submitted it provided flight tickets for the Player’s family to arrive to Bulgaria in
August 2024 and that the tourist visa for staying in the country was valid for 3 months. The
Club argued that the Player’s family failed to present the required documents to stay longer
than these 3 months. For this reason, the Club bought the Player’s family tickets to return
to Brazil.
27. The Club requested the following relief (quoted verbatim):
“In view of the aforementioned, the Respondent respectfully requests to the Football tribunal:
- To confirm that “Contract for Hire of Professional Football Player” and its annex from
18.06.2024 have been concluded between the parties.
- To recognize the termination of the employment contract by mutual consent between the
parties, effective from December 10, 2024 through Act for the termination of the employment
contract.
- To acknowledge that the respondent has paid all agreed amounts under the contract and
its annex to the claimant.
- To dismiss the claimant's request for the award of due compensation in the amount of
48,000 euros, as well as for unpaid salaries, bonuses, and housing allowance in the amount
of 23,000 BGN.
- To dismiss the claimant's request for the imposition of a sporting sanction on the club.
pg. 7
REF. FPSD-18091
- To dismiss the claimant's request for the defendant to pay all legal costs of the case.”
c. Replica of the Player
28. In his replica, the Player submitted that his signature in the Termination Agreement and
the Payment Receipts was forged and underscored inconsistencies between the signature
in those documents compared to his signature in the Contract.
29. The Player further argued that on 10 December 2024, when the Termination Agreement
was allegedly executed, he was not present in the Club’s facilities, as he had been at the
airport since 8:00 a.m. in order to board a flight to Brazil.
30. The Player further submitted that the Termination Agreement had been drafted in
Bulgarian, asserting that, even if he had signed such document, it would be invalid, as he
neither speaks nor understands the language.
31. The Player alleged that, on 4 February 2025, the Club attempted to obtain his signature on
an English version of the Termination Agreement. In the Player’s view, had he indeed signed
the Termination Agreement on 10 December 2024, there would have been no reason for
the Club to request his signature on the same document again in February 2025.
32. The Player maintained that he participated on eight winning matches with the Respondent
and, for this reason, he is entitled to a total of BGN 4,800.
33. Based on the above, the Player maintained his position and submitted the following
requests for relief (quoted verbatim):
“Therefore, is the duty of FIFA’s DRC conclude that:
- The Termination Act shall not be considered as a valid document;
- The payslips cannot be considered reliable documents to this case;
- The Club never paid the rental costs towards the Player or any third-party;
- The Club didn’t attend the Notices sent by the Player;
- On 27 January 2025, there were more than two salaries overdue, leading to the Player
terminate the Employment Agreement with just cause.”
pg. 8
REF. FPSD-18091
Duplica of the Club
34. In its duplica, the Club acknowledged that the Player played a total of 14 matches with the
Club winning 9 of them. However, the Club alleged that the Player appeared as a substitute
in all these matches, and, consequently, he is entitled to only 80% of the agreed bonus, i.e.,
BGN 480 per match, amounting to a total of BGN 4,320.
35. In addition, the Club submitted a forensic report issued by Mr. Nikolay Stefchov Rizov, a
specialist expert in the field of forensic investigation, hired by the Club (hereinafter: the
Forensic Report).
36. The Forensic Report analysed the signature affixed to the Termination Agreement and the
Payment Receipts, comparing it with the Player’s signature included in the annex of the
Contract, and concluded that the signature of the Termination Agreement and the Payment
Receipts belong to the Player.
37. The Club further submitted that the Termination Agreement was signed on 7 December
2024 and agreed that the Player would play his last match on 9 December 2024, after which
he would travel to Brazil on 10 December 2024. For this reason, the Termination Agreement
was dated 10 December 2024.
38. Based on the above, the Club maintained its position.
d. Request for Original Documentation
39. On 18 March 2025, the FIFA general secretariat requested the Club to provide the original
copy of the Termination Agreement and the Payment Receipts via courier.
40. On 1 April 2025, the FIFA general secretariat received the original copy of the Termination
Agreement and the Payment Receipts.
III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
41. First of all, the Dispute Resolution Chamber (hereinafter: the Chamber or DRC) analysed
whether it was competent to deal with the case at hand. In this respect, it took note that
the present matter was presented to FIFA on 4 February 2025 and submitted for decision
on 20 November 2025. Taking into account the wording of arts. 31 and 34 of the January
2025 edition of the Procedural Rules Governing the Football Tribunal (hereinafter: the
Procedural Rules), the aforementioned edition of the Procedural Rules is applicable to the
matter at hand.
pg. 9
REF. FPSD-18091
42. Furthermore, the Chamber referred to art. 2 par. 1 of the Procedural Rules and observed
that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b) of the
Regulations (July 2025 edition), the Dispute Resolution Chamber is competent to deal with
the matter at stake, which concerns an employment-related dispute with an international
dimension between a Brazilian player and a Bulgarian club.
43. Subsequently, the Chamber analysed which regulations should be applicable as to the
substance of the matter. In this respect, it confirmed that, in accordance with art. 29 of the
Regulations, the July 2025 edition of the Regulations is applicable to the matter at hand as
to the substance.
b. Burden of proof
44. The Chamber recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it may consider
evidence not filed by the parties, including without limitation the evidence generated by or
within the Transfer Matching System (TMS).
c. Merits of the dispute
45. Having established the competence and the applicable regulations, the Chamber entered
into the merits of the dispute. In this respect, the Chamber started by acknowledging all
the above-mentioned facts as well as the arguments and the documentation on file.
However, the Chamber emphasised that in the following considerations it will refer only to
the facts, arguments and documentary evidence, which it considered pertinent for
assessing the matter at hand.
i. Main legal discussion and considerations
46. The Chamber then moved to the substance of the matter, and took note of the fact that
this case concerns a claim for outstanding remuneration and compensation for breach of
contract.
47. The Chamber observed that the Player asserted that he had just cause to terminate the
Contract due to outstanding remuneration. The Player further contested the validity of the
Termination Agreement and the Payments Receipts, alleging that his signature had been
forged.
48. For its part, the Club maintained that it had duly paid all salaries, providing the
corresponding Payment Receipts, and that the parties had mutually agreed to terminate
the Contract in accordance with the Termination Agreement. In addition, the Club
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REF. FPSD-18091
submitted the Forensic Report aimed at establishing that the signatures appearing on the
Termination Agreement and the Payments Receipts were indeed those of the Player.
49. In this context, the DRC recognized that it was tasked with determining the circumstances
of the termination of the Contract and the parties’ residual rights and obligations. In order
to do so, the Chamber established that it had to determine the validity of the Termination
Agreement and the Payment Receipts and establishing the legal consequences arising
therefrom.
A. Is it credible the Termination Agreement and Payment Receipts were signed by the
Player?
50.
As a departure point, the Chamber recalled that pursuant to art. 13 par. 5 of the
Procedural Rules, any party claiming a right on the basis of an alleged fact shall carry the
burden of proof. In particular, the Player had the burden to prove his entitlement,
whereas the Club bore the burden of proof to demonstrate that it had complied with its
financial obligations.
51. The Chamber recalled that the above is particularly important considering that FIFA’s
deciding bodies are not competent to rule upon matters of criminal law, such as allegations
of forgery, which fall instead under the jurisdiction of the competent national criminal
authorities. Consequently, the Chamber pointed out that it was incumbent upon the
parties to support their claims with supplementary evidence.
52. Upon careful examination of the case file, the Chamber noted that (i) the Club submitted
proof of payment containing the Player’s signature; (ii) the Player acknowledged that every
payment was made in cash, with the signing of a payslip that remained solely with the Club.
53. In addition, the Chamber paid special attention to the Forensic Report submitted by the
Club, noting that the expert analysis consistently concluded that the signatures appearing
on each of the Payment Receipts, as well as on the Termination Agreement, had been
affixed by the Player.
54. Moreover, the Chamber observed that the Club had duly provided the original versions of
the Termination Agreement and the Payment Receipts, which had been examined within
the Forensic Report.
55. The detailed analysis carried out by the Chamber on each document confirmed the
apparent consistency of the signatures with the Player’s known handwriting and signing
patterns. Similarly, the Chamber considered the Club’s account of the events to be credible,
noting that the Player failed to submit any evidence capable of countering the
documentation on file. Instead, the Player merely challenged the authenticity of the
signatures – an argument which, in the Chamber’s view, was insufficient to outweigh the
documentary evidence presented.
pg. 11
REF. FPSD-18091
56. Consequently, the Chamber concluded that the Club had satisfactorily discharged its
burden of proof and that, despite the technical objections raised by the Player, there was
no substantial evidence that the consent given by the Player had been forged.
57. In view of the above, the Chamber concluded that the signatures on the Termination
Agreement and the Payment Receipts could validly and reasonably be attributed to the
Player. Consequently, the Chamber found that it had to be assumed that the corresponding
amounts had indeed been received by him.
B. Was the Termination Agreement a valid and binding agreement?
58. In continuation, the Chamber turned its attention to the Player’s argument, according to
which he considered the Termination Agreement invalid on the grounds that he neither
spoke nor understood Bulgarian.
59. The Chamber first observed that the Player’s signature appeared only on the original
Bulgarian version of the Termination Agreement, while the English copy remained
unsigned.
60. In this respect, the Chamber referred to FIFA’s well‑established jurisprudence, according to
which a party signing a document of legal significance, as a general rule, did so on its own
responsibility and was liable to bear the legal consequences arising from the execution of
such document.
61. Therefore, in the present case, the Chamber concluded that it was the Player’s
responsibility to bear any legal consequences arising from the execution of the
Termination Agreement and, consequently, his objection in this regard had to be
disregarded.
62. The Chamber further concluded that the Termination Agreement was a valid and binding
document concluded between the parties and that, as established in the previous section,
the payment established therein had been performed and acknowledged.
63. Therefore, based on the totality of the circumstances, the Chamber held that the Payment
Receipts confirmed the absence of any outstanding remuneration in this matter. In addition,
the Chamber concluded that the Termination Agreement superseded any other contract
previously concluded between the parties and served as valid evidence of the consensual
end of their employment relationship.
64. As a consequence of the foregoing, the Chamber concluded that the Player’s claims for
outstanding remuneration and compensation should be rejected.
pg. 12
REF. FPSD-18091
d. Costs
65. The Chamber referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Chamber decided that no procedural costs were to be
imposed on the parties.
66. Likewise, and for the sake of completeness, the Chamber recalled the contents of art. 25
par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
67. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.
pg. 13
REF. FPSD-18091
IV. Decision of the Dispute Resolution Chamber
1.
The claim of the Claimant, Michael Santos Silva Alves, is rejected.
2.
This decision is rendered without costs.
For the Football Tribunal:
Emilio García Silvero
Chief Legal & Compliance Officer
pg. 14
REF. FPSD-18091
NOTE RELATED TO THE APPEAL PROCEDURE:
According to art. 50 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf., art. 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association – Legal & Compliance Division
396 Alhambra Circle, 6th floor, Coral Gables, Miami, Florida, USA 33134
legal.fifa.com | [email protected] | T: +41 (0)43 222 7777
pg. 15