It actually can. It's called swapping. An amazing technology from the 90s.
That's exactly the point of swapping. Memory which was not used in a (relatively) long time is taken away forcefully from the process if there is memory pressure on the system.
So it doesn't matter if Chrome releases it or not, it will be taken away if it just sits there.
To disk. Waiting for the memory a badly behaved app overzealously ate up without using to finish flushing to disk before being able to use it is worse than simply having the memory readily available. This is why I always disable swap, opting to let bad processes die, sometimes even pulling the trigger myself.
In modern systems, paging is okay. But not swapping.
From the 60s. Atlas computer had virtual memory. I originally thought it was the System360.