I don't think non-tr Gardevoir tend to invest as much in bulk. I ran 4/44 physical bulk on one of mine to survive -1 Adamant Kangaskhan Return. I could also see training for -1 Double Edge. Almost every Gardevoir spread I've seen is for semi-TR.The dumbfuck kid that just beat me was running one of my old, abandoned sets and reminded me of it (He won thanks to a double miss on my rock slide + double miss on Icy Wind; this kid was spamming Grass Knot Mega Gardevoir against my Rocky Helmet Cress; GK makes contact and has trash power on cress. How this guy ever got above 1500...).
Anyway, key point: how much physical bulk does Mega Gardevoir generally run? Modest / Timid sets, not TR ones.
Modest @ 100 HP / 252 Def is just barely enough to survive Jolly Return from Mega Kang, and I'm assuming most people don't invest that heavily?
And I thought Char-Y's physical bulk was cringeworthy lol.
edit: Assuming Doubles for everything above.