It has happened people I personally know. It wasn't just a truck passing, it was a truck passing with a good cross wind, which is why it isn't common. This wasn't a small tow vehicle, it was a F350 which is a large truck even by US standards, and it has a heavy duty frame. At least the truck was strong/heavy enough to say out of the ditch and could safely be moved to the side of the road unlike if it was a smaller tow vehicle.