I agree for the most part with your premise. However, nobody is going to make a build where it's a choice between a 10 or 18 con. Typically within the same race and build it is only an option of a point or two of con here or there. For most every build it shouldn't be too difficult to find at least 4 build points to put into con. You'll hardly gimp yourself, and unless you are an elf/drow, you'll start with at least a 12con.