There might be other reasons than optimal solar exposure. Maybe structural reasons, or, I don't know, sap distribution ...
Finally, maybe the Fibonacci sequence gets selected in nature a lot because it's easy to select. What I mean is, the very best algorithms are not necessarily the ones that get selected - the ones that actually get tried and are good enough to survive are the ones that appear. My theory is that organisms stumble into stuff like the Fibonacci sequence or that fern fractal because they are likely to and because they work well enough for whatever purpose.
The problem might just not be "take 10 pieces of a solar panel and find optimal layout", but "take a 5x5x5m volume and find optimal layout". Maybe with a flat panel design you could be able to put 10 pieces at most in there, but it would turn out you could put 30, and at any time half of them are shaded. That leaves 15 generating power, which is more than the flat panel.
I really don't know if it's the case. I just say that everyone is comparing stuff on a wild assumption that you can't put more unshaded panels in a space than on a plane, and so discard a possibly valid solution without attempting to take it on.
Probably we would all see mushroom-shaped trees looking at the sun like Pinus Pinea[1] if it was so optimal. Most trees are not though so there has to have something to it.