Due to the fact that not everyone in the world runs Linux, and, as chip says, FAT is the standard for removable media. Put ext3 on your cards if you want, but the default will always be FAT.
But even still, for the Pandora a non-FAT32 Filesystem would probably be the way to go in most cases. Even if the filesystem isn't readable by Windows, it doesn't have to be. We have things like Samba , NFS and FTP for that purpose. If anyone actually wants to do a Union mount (like has been discussed many times before) they're not going to want to do it on FAT32, since filesystem-level ACLs do not exist on FAT32. I've tried mounting a FAT32 partition to /home/username before and it just doesn't work with Gnome or KDE.
Regardless of the wide support, it is probably better practice to go with EXT3 and just install the EXT3 driver on your windows boxes. Just because it works for everyone doesn't necessarily mean it is the best solution. Linux should run using Linux filesystems.