CheckedNodes is a TreeNodeCollection that only implements ICollection. When the checkChanged event occurs, it probably just adds tree nodes to the CheckedNodes collection.
Nothing to be seen in MSDN implies that you should assume that the nodes will be ordered. All he says is:
Each time a page is sent to the server, the CheckedNodes collection is automatically populated with selected nodes.
From your experiment, it seems safe to assume that in the second postback, it simply adds new checked nodes to the collection, instead of clearing the collection and re-adding everything.
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