The design of the Type 38 is a big reason they are so strong.
Unlike a Mauser the top/left locking lug is solid and unslotted.
They (the Type 38's) were also very carefully and finely made with good heat treatment.
I don't know if I agree that there a LOT of stronger actions made today. P.O. Ackley never succeeded in blowing up an Arisaka either.