I use a PHP-based script to read from a database and send emails out (using the PEAR Mail_Queue library). I run it from within a bash script and based on the returned result (from "exit $status;") either halt, sleep X seconds, or immediately restart. (I also put a check of the load average/sleep into the PHP script to avoid stressing the mail system).
If it was for a long-term daemon that had to be continually running, then I agree, it probably would not be the best thing to run this (though I have heard of some socket servers that did run successfully long term), however, PHP 5.3 does also now have improved garbage collection, and if the script is well written enough to not exit unplanned, then memory should be far less of a problem that before.