That's true - the problem only arises in the circumstances you found in your original post.

I think the place to start looking into this is the _translate sub of ActivePerl::DocTools::Tree::HTML. The title (and subsequent heading in the body) is coming from what Pod::Html generates. I guess possible fixes are

• patch Pod::Html
• pass pod2html a title option which handles these problem cases better (that's what Module-Build and PPM-Make do)
• after generating the html, edit it to replace the title (_translate already is doing such editing for other things)

Update: I filed a bug report (together with a patch) regarding this issue.