It's hard to say if you're implying this is any different with other validation levels like OV and EV. The validation methods that CAs may use for OV/EV are the same ones they may use for DV. The only difference is that they also validate the organization's information of the certificate requester. In other words, someone with the ability to MitM traffic between the CA and the target's domain could still obtain an OV/EV certificate for that domain, they'd just have to verify they are who they claim they are on top of that (and they don't have to be the domain owner - there's nothing that says "only the legal entity owning the domain may acquire a certificate for that domain").