Possibly. My phone is often placed on the side in a factory, used outside when testing and exposed to the elements, dropped off my desk, used by my two children (3 and 6yrs)... So it gets quite a bashing. I wouldn’t want to be babying my phone though as I like to use it without worry. I’m not keen on the feel of iPhones without a case on personally as they seem so slippery, unergonomic, and fragile. I like that a case adds thickness and grip.
All legitimate reasons to use a case.