This could be a significant issue. On my PC I use Thunderbird, and display both of these dates. I can choose to sort by either. A tiny minority of my messages from past years, though not recently, have dates either of 1_1_1970 or some time in 2036. Respectively the earliest and latest dates *nix systems can create, i believe.
I also had to track down why I was not receiving certain business emails in a timely fashion, and in some cases up to 4 days had elapsed between ' Date: ' and ' Received '. This prompted the sender to discover a problem with his service provider.
I would not like to have a non-optional change to use the Received data, as messages can and do swap order when you change between them. Configurable would be good.