If it's the former then I think that absolves the author.
I do not think the author was purposefully being misleading. I do not think they need absolution for anything. I think it may be interperted as misleading by some (as it did for the original commentor) based on the reader's recent experiences with Unity and the latest drama; which is not a property of the article, the headline, or the author - but the reader.
"Unreal Engine starts charging for non-game development".
It's not about space, and we know it's all too easy to bury the lede and leave the internet to lash out as it is oft to do. But I don't blame the author. I know in larger sites editorial will make the title without context of the writing independent of the contents in order to maximize traffic.
Headlines don't have a lot of space!
And as I said in a different comment, the subheading seems to address the main complaints, and in most situations you'd see the headline and the subheading together.