I have had good success bottling from the keg with a beergun between 3 and 4 vol CO2. Granted some is most likely lost during the bottling process, but I have achieved close without bottle breakage even in the crappy homebrew shop bottles.
I do agree with others here that rough handling can play a role in breakage, but it can be done. Also helps if bottles can remain cold for most of the storage time prior to being judged.