The Zend Framework Manual says the following:
60.3.1. Escaping Output
One of the most important tasks to perform in a view script is to make sure that output is escaped properly; among other things, this helps to avoid cross-site scripting attacks. Unless you are using a function, method, or helper that does escaping on its own, you should always escape variables when you output them.
Why 'always'? Why do I have to escape variables that have not been created or altered by user input?