This worked at least differently in struts 1.3.x:
If your default resource file is called ApplicationResources.properties (all others are called eg ApplicationResources_de.properties) it should fall back to that one in case you have a browser set to a non supported locale (eg if missing ApplicationResources_bg.properties).
In struts 1.5 it resolves to the locale from the server instead to ApplicationResources.properties, which is a strange behavior I would say.
I will try to investigate, maybe I can find out what changed that.