I build and work on a lot of wheels and rarely build any wheel with less than 32 spokes and often build with as many as 40... just finished a wheel for a customer and it is a 36 / 4 cross wheel built with a SA AW hub and 27 inch rim for a vintage build. The front wheel on the bike is also 36 spokes / 3 cross and it will be used for daily commuting so strong wheels were the order of the day.

If I did my job right these wheels will not need to see a spoke wrench until the rims wear out... and I do my job right.

I run a 32 spoke rear wheel on my commutourer, have a 32 spoke rear wheel on my extrabike that carries excess amounts if cargo and have a 32 spoke rear wheel on my fixed road bike that only carries my 142 pound self... these have never needed any touch ups and they all see some decent mileage and abuse.

You can't go wrong with a 36/3 wheel, especially in the rear... I build plenty of touring wheels with this configuration and also build a lot of 36/3 and 36/4 fixed wheels for utilitarian riding and commuting purposes.

My vintage racing bike uses 36/3 lacings on 27 inch double walled and eyeletted rims... these are very strong and very light wheels.

You can build a strong low spoke wheel but to do this you need a heavier and stiffer rim which cancels out any weight savings you got by reducing your spoke count... these fewer spokes will be under more tension and if one spoke fails the wheel will fail whereas with a 36 spoke wheel you can often limp home if you break a spoke.

I have seen old Raleigh 3 speeds come into the shop with numerlous broken spokes in the rear and not had the rear wheel go out of true to any significant degree... many of these are 40 / 4 cross wheels.