John Mueller from Google said just because a web site was once penalized, it does not mean it cannot be penalized again for the same issue. It is not like when you get a specific virus, that if you survive it, you become immune to getting that specific virus again. You can be penalized by Google for the same issue more than once.
Here is where John said this:
— ? John ? (@JohnMu) February 23, 2020
This is not new, we’ve seen sites get hit for the same issue more than once.
In fact, Google has said that the second time you get a manual action can sometimes lead to harsher and longer penalties.
Although, it would be cool if a site can be immune to a penalty it received in the past.
Forum discussion at Twitter.