Yeah... you'd have to figure that S-Prime added a little superstrength on top of that resurrection, because even if Bruce didn't spring for a burial vault, there still would have been a grave liner, which would have been enough to stop Jason from digging out, even if he didn't need to breathe. Then again, it would also keep almost all zombie stories from happening.
*The only exception that I know of is the book Pet Sematary, where this is accounted for.