Was it an actual leak or just seepage that develops given enough time. Did you actually see it beforehand and where was it located? With normal seepage that really isn't much more than a smudge that can be wiped off and takes a long time to reappear, some dealers will call it a leak and quote a multi hundred dollar repair. It's a money maker for them.
Having said that, last year at 71k miles I replaced the valve cover gasket because I discovered a very small amount of oil at the base of #1 spark plug. Not being in the habit of removing the coil packs and peering down the plug wells for inspection purposes I wouldn't have discovered this unless I was ready to install new plugs, which I did afterwards. Beyond that I can't recall even any seepage elsewhere much less an actual leak from the valve cover.
I don't know your maintenance/inspection habits but I would think that given your operating environment your engine compartment would accumulate much dirt and a good time to spot leaks is look for fluid soaked or damp dirt after removing the engine cover and prior to washing down the engine and surrounding compartment and components. Hard to spot leaks when everything has just been washed. Just my 2 cents.