That's ridiculous. Spokes are cold formed wires, nothing more. Sure, a crappy spoke may break at the J-bend under extreme circumstances, but assuming they're tensioned right, a "bad" spoke does not equate to a bad wheel.

I think you're confused with bladed, butted, dbl butted, etc.

OP, if you have the option of a 3x 36h setup, go for it. The nominal weight difference isn't really comparable to the increase in strength you'll get.