Ness's reflector can break, just like everyone else's. The Villager trees do like 30%-35% damage, so naturally they wouldn't break outright. But, it doesn't break like Fox's does. Something...weird happens. Instead of him taking the hit outright, he suffers INSANE endlag on the bat, so it's like punishing a ****ing Rest!
https://www.youtube.com/watch?v=wV89zj4MJ8Q
However, there is no projectile anywhere in the game's data that does enough damage to break a reflector outright. So, this will only really happen when you bat a strong projectile that they just reflected from your bat after they initially shot it.
Confused? Don't be; it'll never happen.