I've had memory errors make many directory entries disappear in one directory on XFS, noticed only months later. When you write out bad data and the computer says everything is fine, you won't necessarily be able to get your data back.
https://en.wikipedia.org/wiki/XFS
(and I don't use XFS any more.)
It feels like arguing in bad faith. How did you arrive to the point XFS is non-journaling to begin with?
And if it doesn't help, then why you decided to bring it as an argument?
NB: even if you use ZFS you still need backups.