FWIW, my bike came with two crappy, cheap machine-built 36 spoke wheels, and I broke a dozen spokes in the first 1500 miles or so.

I then bought good spokes and a new rim and built my own rear wheel (my first build), again 36 spokes. After 4 years and about 15000 miles, when the axle finally broke (it was a cheap freewheel hub) it still was in absolutely true without me ever having touched it again after building it. And again, this is over rough road that broke a bunch of spokes with a factory wheel.

I was worried about proper tensioning, and was thinking about buying a tension gauge, but a friend said "just slowly ramp up the torque, keeping the wheel in true at all times. Keep going until it feels like you're about to strip something." It worked for me, and I later built a front wheel around a disc hub, and that one also is absolutely true after 8000 miles of riding.