Linux itself creates a FAT partition for /boot, because the UEFI standard supports loading from FAT.
As well, if you ever look at a live-CD (like the installers for most modern Linux distros are), it will usually be using SYSLINUX, which limits itself to 8.3 filenames, for various good reasons to do with floppies, PXE, and ISO9660. Mount an Ubuntu CD in Windows and you'll see them.