Most likely those with failures had modified/deleted/renamed something else that was causing the issues and blaming it on the frozen apps. I have updated every device I've had with frozen apps. Freezing, at least in Titanium Backup, tells the OS the app is not available. In recovery, the OS is not loaded and knows nothing about frozen apps. Titanium doesn't touch the actual files so they are still present to be patched by the OTA.
Sent from my Nexus 10
Motorola Droid, Droid 2, Droid 3 and Droid 4 (all rooted)
Motorola Moto X DevEd - KK 4.4.2 + Root
Google Nexus 10 - KK 4.4.2 + Root