Like most have said it mostly depends on who the heels is. Guys like Khali, Sheamus and Mark Henry should not be resorting to count outs and DQs to retain titles, when they spend 6 months obliterating people to get their title shots in the first place.
But why can't heels win just by being smarter than their opponents like Chris Jericho or Edge tend to do? Ok Edge is probably one of the top ten 'cheap victory' champions, but there are times where he does simply outsmart his opponent.
Look back to 2000, Edge and Christian (posing as Los Conquistadors) vs The Hardyz for the tag titles. Edge and Christian had spent the better part of the year being DQ'd or counted out, or relying on outside help, but in this particular match, they manipulated their opponents and then beat them fair and square. At no point do E+C cheat in that whole match. Matt and Jeff spend the entire time trying to take the masks off their opponents to prove that it's really E+C, and when Matt pulls Edge's mask off, only to find a 2nd one underneath, Matt is caught off guard for a split second, giving Christian the chance to hit the Unprettier, 1,2,3, new tag champs.
Take Chris Jericho's fued with Rey Mysterio a year or so ago. The match that stands out to me of the whole fued is when Jericho ripped Rey's mask off his face as he was executing the 619, and then rolled Rey up as he was covering himself.
He didn't cheat per se because Rey wasn't blinded or anything, Jericho simply took advantage of Rey's weakness, which was his need to protect his heritage over his need to win the match, and Jericho regained the IC title.
Wade Barrett beating Cena due to Harris and McGuillicutty interfering, would also be acceptable to me. The occassional run in, where the heel actually gets the 1, 2, 3 as a result and not gets DQ'd as a result, would also be acceptable to me personally, but when heels just go and grab weapons when they can't get the pin or just walk off time and time again is just lame. It doesn't make me hate the heel more, it makes me hate the bookers more for allowing the match to end like that A-GAIN!
And they need to stop focusing so much on heels HAVE to be booed and faces HAVE to be cheered. This is the age of the anti-hero. Assholes are still cooler than goody two shoes.
Who got over the most 10 years ago by being grade A assholes? The Rock and Austin.
And why does every heel have to be cowardly? Look at just about any other form of entertainment with good and bad guys. Does the bad guy always run away from the hero and hide to avoid getting beaten? Or are there some villains who kick the living shit out of the hero for ages only to lose in the end anyway?
Wouldn't Dragonball Z have been really shit if everytime Goku appeared the head villain had run away?
That's what was good about Kane's title reign. The guy actually won the majority of his matches without cheating. He was actually dominant in his title reign and lost in a multi-man format. The only thing wrong with Kane's reign was that he only ever wrestled people who he'd wrestled countless times in recent years, so it seemed old before it started. But what was fresh and new about it, was the heel champ was actually defeating his opponents, more often than not, without help.
Ok Paul Bearer shone a light in Taker's eyes at HIAC. Big whoop, stupid angle, Kane hits the tombstone, still a clean win in my book. He DEFINITELY got a clean win the month before. Month after Nexus came out, well we STILL don't know why that happened, probably just to set up Barrett/Taker, plus has there EVER been a Buried Alive Match where there wasn't a run in? And then he had a draw with Edge and lost the PPV after that. Week in and week out on SD, Kane kicked ass and never ran away from anyone.
And what about Kurt Angle? Did he take cheap count outs and DQs to retain titles or did he twist ankles until the guy was tapping? That's right, the latter. If every heel is supposed to be a coward, why did Kurt Angle make people like HBK and Hulk Hogan tap out?
The answer there of course, is that that was in 2001-5 and Angle is an Olympic Gold Medalist. It's 6 years later and we've got Sheamus, who embodies a Celtic Warrior, smacking Orton with a chair immediately after he kicks out of Brogue Kicks to keep the title.
If we're talking about Miz, then no he doesn't need clean victories over someone like Orton, because the guy became champ via a cheap MiTB win. Guys like RVD, Kennedy, Edge, CM Punk and other MiTB winners, had at least had fueds with ME talent before they got handed the briefcase. Swagger and Miz hadn't fueded with anyone outside of the mid-card, so it wouldn't be believable for Miz to get a clean win over say Edge or Cena, so i understand why he has to resort to DQ's, run-ins etc.
But Sheamus, a 2x champion, KOTR and the guy that took out HHH from active wrestling, needs to hit Orton with a chair in order to retain? When HHH has made Orton his bitch more times than most people can remember? That equation just doesn't seem to make sense to me in terms of logic.
