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Never.
1. SE can't estimate the quality of the text.
2. without enough backlinks your content can even be not completely indexed (even unique and very valuable)
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Nobody's saying that backlinks aren't important. They are. Some people just prefer to let others do the backlinking work for them naturally while they focus their work entirely on content-building. Everyone does SEO differently.
Scenario 1 - Some create a small site and work their butt off submitting to directories, posting in forums, writing articles...
Scenario 2- Others just continuously keep building content and get natural backlinks from visitors to their site, without ever paying attention to backlinks. Either way, you'll get indexed and you'll get backlinks.
Scenario one is risky if Google sees that you're doing anything unnatural, but it is a quick way to rise in SERPs and get indexed quickly. The downside is that while you've been spending so much time getting backlinks, those competitors who chose scenario two have overtaken you in content-building. Scenario 2 is safe because you're not manipulating backlinks and thus can't do anything black hat in that aspect. But, indexing will be slower and you will remain low in SERPs. The good thing is that if you are patient, you will have gotten backlinks without putting in any actual link-building work yourself. Your visitors will do it for you. You will also have a mega site because your focus was on content. Thus, if you are patient enough, you will go up in SERPs and start getting indexed more frequently. It's just that scenario 2 requires a lot of patience.