The reason VS mode is frowned upon is because if not watched it could potentially lead to this exact scenario.
The fact still remains that the aircraft needs to be watched whatever climb mode is being used. Not paying attention when using FLC has the potential to lead to descent, and climbing in pitch mode can also lead to a stall.
There is no one climb mode that offers foolproof protection, and all three modes do have useful purposes.
Paying attention towards TOC is key. So too is understanding aircraft performance, and that climbing too high too soon is a waste of time and fuel.