This is seriously an example of why football fans, and especially media members, generally aren't scientists.
I get their point, but it's hardly a new one. Recruiting has ALWAYS mattered, and generally, going back probably to the 70s, every NC team has been among the top 10 in recruiting more often than not.
But, that doesn't mean it's impossible for a team that doesn't land in a Rivals Top 10 list to win a championship. It's already been explained by DenverRed, but here's a picture to summarize:
The issue here is that they are taking the past record over 20 years, during which time, 3 teams varied from their assertion, by the way ('94 and '95 NU and '00 Oklahoma), and acting as those it's a necessary component to winning an NC. It's not, necessarily, and it's obviously not a sufficient component either (see ND with it's 4 straight top 10 classes or whatever).