Are these file recovery apps running on the phone or on a computer? Just for information.
There's no special reason a recently-deleted file should be less recoverable than an old one, assuming that they are on the same storage device, i.e. all on internal storage or all on removable storage - if they are on different storage devices then that could be a factor. Assuming no insuperable technical problems (e.g. trying to recover data after a factory reset has erased the encryption key, which is a common one) the commonest cause of file recovery failure in general is overwriting of the data you are trying to recover. As a rule of thumb you might think that files that were deleted longer ago would be more at risk of that, but it depends on the whims of the storage controller's algorithms (which I'm not an expert on by any means) - I could speculate about whether a block of released storage (a deleted file) is more at risk if it's in the middle of a section that is in use or at the start of a block of unused storage (more likely for the most recent file perhaps), but that would just be speculation.
Practically though it doesn't help you either way. There's no "switch" that says "don't recover files that existed for less than an hour", and hence there's no setting you can change to make the file recoverable. So unless you can identify something that's different about this file (and being stored on a different storage device is the only really relevant thing I can imagine) I doubt there's anything we can do.