A day-one patch is the day of the release, so it counts as included in the release in my books.
It doesn’t mean « they haven’t done enough testing before physical production », it means they took advantage of the inevitable several weeks or months between start of physical printing and release.
And of course a patch 1 year after release is fine. What I’m saying is that I prefer a broken game that is fixed on release day over a broken game that is fixed 1 year later.