OK, YES, it can.
Detail:
I rebuilt the front axle with all Toyota seals, Kits from Cruiser Parts. I was meticulous about cleaning, aligning, fish-scaling everything. This is NOT my first rodeo, as I have been wrenching for 45 years. Grew up on a farm, rebuilt my first engine at 10YO. I built a 4WD Chevy for a 4-H project, so I know what to do.
Rebuilt everything, new bearings, new seals, new rotors, new axles (RCV), new brakes, new calipers. Lubed all parts before assembly. Used a torque wrench on EVERYTHING. Moly in the knuckles, Red-N-Tacky on wheel bearings 85-90 in diff.
Started DD the truck and within 5000 miles, I had Birf Soup on the RF knuckle. Everything was new, so it wasn't a matter of whether the seal was aligned in a groove. I had no trouble stabbing the axles, so I had no concerns with the inner seals from an assembly standpoint. Folks here advised to stay away from Marlin seal for a DD and I did. Only Toyota seals in there.
I checked out the axle vent housing and it was pretty cruddy, so I took it off and cleaned it. I removed the hose and it was clogged. I removed the fitting from the axle housing and I had to use a dental pick to remove the solidified gear oil and grime from the PO. Then I reinstalled the fitting, added about 5 ft of 1/4" fuel hose and a fuel filter as a vent and draped it up over the brake booster.
I sucked out the birf soup from the knuckle, and changed the differential oil.
The problem has gone away and never returned in 65K miles.
With the axle vent clogged: On a long drive, the axle housing would heat up and pressurize. The pressure would force the gear oil past the seal , into the Birf. As it cooled, the housing would go to a vacuum and suck the gear oil/grease mixture back into the housing creating Birf soup in both the knuckle and the differential.
Since I cleaned the fitting and installed the long vent hose and fuel filter for the vent, I have not had Birf soup again in 65K miles. I have never opened up the knuckles again.
So, yes, it CAN, and will happen if the conditions are right.