I bought a Dell M1330 laptop a few years ago and the speakers were crap even by laptop standards. This was fine with me, since I planned to use headphones. Unfortunately, the audio output was just as crappy! It had an insanely high noise-floor! I had to get a USB DAC/head-phone amp to make things acceptable. Lesson learned: Dell sucks at audio.
If the speakers in a consumer device like a laptop can be damaged by maxing the volume then the laptop was not properly designed. This isn't a case of a nutty audiophile mixing and matching unknown preamps, amps, and speakers and managing to blow some cones by cranking it to 11. Dell has complete control over the selection of components in this laptop and, if they cared to, could include circuitry to limit power beneath a point that will damage the speakers. They didn't. Alternatively, they could eschew a limiter and select speaker components beefy enough to handle the maximum voltage that their DAC's can output. They didn't. Bad design.
If Dell did the math and decided the number of users noticing permanent speaker damage would be small enough that the reduced part costs would outweigh the price of the resulting warranty service, that's their decision. However, they should be on the hook to fix damaged caused by their cheap/poor design.