Sure, it "could". Except that the top Google engineers described this factor specifically many times. The fact is that recovery no matter what is extremely rare - except when the algorithm changes as it just did in Panda 2.3
I would definitely not overwhelm the content at the top of the page with ads. Even without Panda, I wouldn't do it. It's manipulative nonsense in my view.
Anyone is welcome to do what they want, obviously, but if I visit a page like that, I'm out of there as quick as I can. I'm amazed that the ploy works on some people.