I've had the same experience the two times I've tried btrfs, about two to four years ago, in my case with Linux VMs that would occasionally be abruptly terminated. In both cases, the corruption that couldn't be automatically repaired happened within the first few of these sudden terminations.

Ext4 seems to handle that scenario better. I can't think of a single instance of filesystem corruption that fsck couldn't fix, and some of those VMs have probably been abruptly terminated at least a hundred times over the years.