It's not obviously true at all. Optimizing out `'' = 'x'` can be done for a fixed cost regardless of record count.
But of course, in normal life, outside of the world of people having fun with Homomorphisms, queries are much smaller than databases.
The only losing case, if there are any measurable ones, is where you have long queries and short data. I'd call that a case of "doing it wrong". Wrong tool for the job.