The real need for the WP_Filesystem is to be able to set the correct file owner/group permissions when writing new files. Reading or overwriting existing files does not change these permissions so the WP_Filesystem is not technically needed for that (though you can use it for that too.)
The reason is it is a potential security risk to write new files without checking owner/group permissions as there is a chance they may be alterable and thus injected with code and executed (mostly on shared servers with poor security, but if the case of plugins and themes you cannot know the end user’s setup.)
Reference: http://ottopress.com/2011/tutorial-using-the-wp_filesystem/#comment-10820
Question: If you are only getting contents of a file, you do not need to worry about getting credentials, correct? You are never writing a file to the server, so there is no issue with file ownership. Similarly, if you are updating the contents of a file that already exists, you are not creating the file, so again, no issues with file ownership, correct?
Answer: If you’re reading a file, there’s no issues. If you’re updating a file, while there are no ownership issues, you shouldn’t be updating a file in a plugin or a theme because the updates will be lost when the plugin or theme is upgraded. Which means that to maintain across upgrades, you need to create a new file outside the plugin/theme directory, which means you should still use the WP_Filesystem.
So in answer to the question, for the plugin and theme editors it is not technically needed as they are only editing existing files, you cannot create new ones with them. (Therefore it is somewhat assumed you know the changes will be lost if you update a plugin / theme later without taking steps to preserve the changes.)
But in a broader sense, the question could be considered as “when should/must the WP Filesystem be used?” Since it outputs a user admin form (when the correct permissions are not already in place) it must be used for admin facing options when creating new files (typically via settings pages.)
If creating new files can be avoided (as is often the case) that is often better, as it can confuse the user why credentials are being asked for (unless you add something to explain it!) If you must create new files, use the WP Filesystem. Similarly, you will probably want to use it for creating directories for similar reasons (although directories cannot be executed.)
Better practice is to use it for updating files too where possible, as it can alert the user to the possibility their ownership permissions on those files are wrong – they will get the form (but again not know why unless you explain it!) – but it is not strictly necessary. Using it for reading files can be done too (but not at all necessary.)
There are exceptions of course and in the end it depends on the use case. Further discussion on different use cases is found via the same link provided.