You never mentioned a specific program, so I still don't know if this is a real world bug you're running into. Either way, your logic is flawed, as fileOp.pTo is a single directory in this case, so using FOF_MULTIDESTFILES is wrong.
MSDN: FOF_MULTIDESTFILES The pTo member specifies multiple destination files (one for each source file in pFrom) rather than one directory where all source files are to be deposited.
As I understand, FOF_MULTIDESTFILES must be set, when pTo is directory
The program is Garant 7 F1 (Russian legal system database). I don't think you know this program. It is not a real world bug, but there are some significant bugs in SHFileOperationW. I don't think a lot of programs use SHFileOperationW to move a files, so these fixes maybe don't fix bugs in bugzilla, but is it criterion why pathes wouldnt't be applied? I solve these bugs for Etersoft. Now in Etersoft wine Garant installs perfectly. But I want to fix these bugs in wine. I don't think my patches are perfect. I can fix them if you say what's wrong. I used to write a tests, but even a tests are ignored. Without any explanation. I was resending them, but had no answer again. Sometimes I think it's just waste of time. I have a lot of patches which I could send, but I think they wouldn't be applied just because they don't fix any "real world bug".