I'd say a lot of users are going to borrow patterns from Go, where you'd typically check the error first.

    resource, err := newResource()
    if err != nil {
        return err
    }
    defer resource.Close()

IMO this pattern makes more sense, as calling exit behavior in most cases won't make sense unless you have acquired the resource in the first place.

free may accept a NULL pointer, but it also doesn't need to be called with one either.