Rainbow Six already used it (1080p + 60 fps). Killzone Shadow Fall used similar (but simpler) technique in multiplayer mode (1080p + 60 fps).The problem with checker-boarding is that it's almost too good. Devs are probably asking themselves why not use it to reach 1080p on vanilla ps4 with half the samples to shade. At this point, the difference from actual native 4k (with uncompressed pixels) to what pro will be able to output will be more discernable.
Checkboard works better in 60 fps games as reprojection errors are halved. 4K makes pixels 4x smaller also reducing errors of this technique. Seems that it works pretty well @ 30 fps as well (at 4K). Most likely 1080p @ 30 fps would show more errors.