No noise cancellation is better than bad noise cancellation. The ANC on every set of earbuds and headphones under $200 I've tried is just a blast of white noise that makes it feel like someone is ramming cotton balls into my ears with a jackhammer.
I guess it depends on the use case. ANC on my FreeBuds (which are open type) is certainly limited, but it's a make or break difference in e.g. public transportation.