Well, let's look at the facts. Despite the fact that Marvel keeps adding Sorcerers Supreme willy-nilly (which has led to Yao losing and regaining the title several times for no apparent reason) we've only seen the mantle pass a handful of times:
1. Marvel Premiere #10 (1973). The Ancient One dies, but passes the mantle to Stephen before he becomes "One With Eternity".
2. Doctor Strange, Sorcerer Supreme #61 (1994). Strange willingly passes the "mantle esoteric" to Salome (but keeps the Cloak & Eye).
3. Doctor Strange, Sorcerer Supreme #75 (1995). Strange regains the title when Salome is defeated. Note that at this time she "had the Vishanti's favor", but he had renounced their patronage. He was still the Sorcerer Supreme, though.
4. New Avengers #51 (2009). Stephen relinquishes the mantle due to the overuse of dark magic. The position is vacant until issue #54 when Jericho Drumm is appointed to the mantle.
5. [New Avengers v2 #6 (2010). Jericho sacrifices himself to defeat an apparently insane Agamotto. The mantle is vacant.
6. [New Avengers v2 #34 (2013). Agamotto gives the mantle back to Stephen.
(Note that 4-6 were all written by the same writer.)
7. Doctor Strange #381-385 (2018). Loki somehow spoofs the Trial of the Vishanti to become Sorcerer Supreme, although whether he actually holds the mantle is unclear. By the end of the storyline, Stephen has it back
8. Death of Doctor Strange #5 (2022). Clea becomes Sorcerer Supreme of her second dimension on Stephen's request before he passes on.
If you look at the list, the mantle only passed by means of the tournament once (twice if the Loki thing was at all genuine). It's been passed by simple bequest more often.