I'll still not committ 100% to it, but that just doesn't look bent to me. It could very well be simply that the paint is of a more brittle variety than usual. If it were in a minor collision those are some of the spots at which the frame would flex and it's possible that's all that happened - the frame flexed, but didn't move past the elastic limit, and the paint cracked at the points which moved the most. I once straightened some serious damage in the same area in which the tubes bent far enough to ripple them on the undersides and the paint just flexed, both during the initial bend and while I was bending things back. I suppose if something like that can happen without a single bit of damage to the paint, the reverse is possible as well.