The only way paypal can tell if a buyer received an item (if they have opened a dispute for non receipt), is by the seller providing trackable proof of delivery of the item to the buyer.
If not then you have to refund and claim from RM if you sent with tracking / insurance and it got lost.
You don't have to send trackable but if you choose not to then its at your own risk and not the buyers.
After all if you paid for an item and didn't receive it then you would want a refund as well wouldn't you. 
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