Its down to how the payment was sent to an account.
1. If sent using money > goods / services option then paypal would see the recipient as a seller and apply the new seller hold. They would also charge a fee.
2. If sent using the send money > family / friends option then the recipient would have the payment instantly (as long as it wasn't an echeque pending with a clearance date) with no fee if funded from a bank account or balance (a fee if you use a card). (However that option is not available in every country).
Advice is voluntary. Kudos / Solution appreciated.