Unless this are enterprise disks with capacitors anything can happen when it suddenly looses power. Not the FSes fault.

Most filesystems just get a few files/directories damaged though. ZFS is famous for handling totally crazy things like broken hardware which damages data in-transit. ext4 has no checksum, but at least fsck will drop things into lost+found directory.

The "making all data inaccessible" part is pretty unique to btrfs, and lets not pretend nothing can be done about this.