I wasn't aware musl implemented libres. I don't have a problem with libres doing TCP.
Qmail's issue was a hardcoded buffer size so this patch to musl wouldn't have helped.
The point wasn't that this would have helped Qmail - Musl didn't exist back then for that matter -, but that running into the 512 byte limit and needing TCP fallback was already a thing. Bumping a buffer size is far less effort than having to replace the resolver.
However musl also includes res_send() etc., which can be used for MX records, and e.g. Qmail did use it back then. Here's the commit adding TCP support to those functions in Musl.
http://git.musl-libc.org/cgit/musl/commit/src/network/res_ms...