If you are sending a small amount of data it is likely a tiny overhead for some notable benefits.
1. If all data is encrypted then no data stands out for being encrypted.
2. It provides integrity which may prevent push servers from changing message to be invalid or triggering parsing bugs in applications.
3. If only encrypted messages are supported it is impossible for uses which do need encryption to forget to turn it on or accidentally turn it off.
For many apps the benefit here is indeed tiny, but so is the cost. So I think it is best to not support unencrypted messages altogether.