Is Fake Mail DeaD?

Well,
I was just going through some recent fake mail softwares and php codes. I couldnt help but notice that even though almost all of them worked, every message sent ended up in the Junk Folders.
I tried this on Hotmail and Gmail but the Spam Filters of both these Services kept the Fake Mails out.
So is this the end of fake mail or is their a possibility of writing code that could bypass the Spam Filters? I wouldnt discount that possibilty cause of the huuuuuge advances in php codes recently..