Forum Moderators: Robert Charlton & goodroi
A page can get good rankings on a particular keyword search if that keyword is in the link text on a different domain or even just in the title tag of a linking page. In the absence of spiderable content on the page itself, these off-site factors can be dominant.
Also, the page in question may still have at least a title element of its own (in the head) that is not generated through javascript -- that also has major clout.
There are also some technical tricks to show false PR on the Toolbar, but I doubt that anyone who writes an entire page with javascript is using those.