Maybe I'm mistaken, but this sounds more like an argument for edge stability than knife toughness.
A knife can be incredibly tough (i.e. difficult to break) but not hold and edge well. It may not microchip, but it means frequent sharpening, and we're right back to square one.
Also, don't forget edge geometry. If you have an edge that is chipping, making the edge geometry slightly thicker may solve the problem completely. Geometry can solve many, many problems.
And of course what you prioritize should be determined by what task you want the knife to perform... but I'm not going to get into that.
For a general purpose knife, I think it need to be tough enough for normal use, hold an edge long enough to get through a normal day, and be able to hold a good edge angle without issue. If it is lacking in any one of those, you'll likely end the day frustrated.