I would not generalize across technologies because in
the end ESD protection is more about design choices
(such as whether to place even one ESD diode on a
pin, if it impacts die area, which it must).
I do believe that bipolar devices are, at the low end,
more rugged than a MOS gate in the sense of
catastophic unrecoverable failure, but bipolars can
still easily get drifted enough to fail spec at low
voltages (really, the avalanche time*current profile)
and fixing that on a coarse geometry, high common
mode voltage range pin is all kinds of funsies (if
it'll fit, and work, which is part negotiation and part
"Fun Surprize Pak!".