I'd say that the reason why the parser does not complain about line 8 is that it has no valid reason to say an ERROR element cannot contain another ERROR element.
In order for the parser to know this you would have to use a DTD to describe the valid document tree.
Consider this syntactically valid set of tags:
Now, if you remove the last line, the XML becomes invalid. It would be tempting to fix the problem in line 4 but this would give a completely different document structure.
Time flies when you don't know what you're doing
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