Chances are a lot of machine learning implementations can be replaced with just "boring" statistical models and achieve more power.
OTOH plenty of creatures don't need to learn. Does a mosquito need to learn? No, it spawns thousands of offspring and doesn't live very long. The high spawn rate means you have a wide variety of natural mutations in your offspring, meaning one or a few of them are likely to have higher fitness in a given niche. It doesn't matter if most die if a few go on to survive. This is the strategy many organisms use to dominate the world in far greater numbers than our own species.