The PS3 makes it easier for patches but Gabe hates Sony. He couldn't be arsed to port it to OpenGL so it simply runs "shit" compared to how it fairs on the Xbox 360; where it should perform so, SO much better.
To be quite honest i'm not sure why they bothered bringing orangebox to the console's, with all the bugs we're aware of, that are now fixed for PC versions; console TF2 is essentially broken. Sure they wern't aware of them at the time, but unless they have a way of bringing these important patches to the whole community, it's a waste of time.
Don't get me wrong, some fps games do play well on Console, Time Splitters was brilliant, 007 games.. But not tf2. I played HL1 on PS2, it was terrible.