I was more curious so I looked at the code here:
https://sqlite.org/src/file?name=src/pager.c&ci=trunk
and found something similar to what you are asking in this comment before `sqlite3PagerCommitPhaseTwo`:
** When this function is called, the database file has been completely
** updated to reflect the changes made by the current transaction and
** synced to disk. The journal file still exists in the file-system
** though, and if a failure occurs at this point it will eventually
** be used as a hot-journal and the current transaction rolled back.
So, it does this: ** This function finalizes the journal file, either by deleting,
** truncating or partially zeroing it, so that it cannot be used
** for hot-journal rollback. Once this is done the transaction is
** irrevocably committed.
Assuming fsync works on both the main database and the hot journal, then I don't see a way that it is not durable? Because, it has to write and sync the full hot journal, then write to the main database, then zero out the hot journal, sync that, and only then does it atomically return from the commit? (assuming FULL and DELETE)