Well... I called legit (a government agency that help people to apply for immigration in the H&C, asylum...) and I explained the situation and asked to man on the phone to be frank, blunt, to tell it like it is... Well, he said based on the way she came to Canada (international student spouse), I told him i am a french citizen, and well, he said at first her chances were 75%... then further I explained what the cic said in the letter, how was the letter she sent, and he said 90% refusal... then when when I told him what was in the letter she sent, he said that this letter will simply be dismissed...Technically it's possible to get approved without a PCC. However it has to be impossible to obtain the PCC. My husband was approved for PR with one PCC missing. He spent a year and a half in Kuwait before the war. All of the records were destroyed in the war and it was therefore impossible to obtain a PCC for that period. We tried for many months to get once - including contacting multiple embassies and consulates. CIC accepted our letter and evidence (all of our communications with the embassies/consulates) - and approved his PR visa.
So it is possible to be approved without one - just don't think it's going to work out for your wife. In her case it is in fact very possible to obtain the PCC - she just can't be bothered to try. I don't understand this lazy approach. Why bother applying for H&C and wasting tax payer dollars if you can't even be bothered to do the required paperwork?