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I wouldn't say clustering is just for patching. It's also for immediate fault tolerance. With a single firewall VM, if the host running it tanks for whatever reason, the vCenter can start it on another host, but it generally takes about 90 seconds before the VM would be able to pass traffic. Potentially much longer if it's trying to start other VMs at the same time (storage contention is painful).
If you can tolerate an outage like that, cool. If you can't, you would need either VMware Fault Tolerance (which limits you to two vCPUs or an unbelievably expensive license) or a cluster of VMs with DRS rules to ensure they're physically distant.
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