Patches too small to be worth the overhead?
Well, 500MBs to 1GB seems to be the "sweet spot" for BitTorrent... anything more and you're risking the seed disappearing before anybody finishes, anything less and everybody finishes and goes away so quickly that the torrent only lasts a few hours... :)
Having each package being it's own torrent, for only about a few MBs, just wouldn't really provide much benefit, unless there were hundreds of people downloading at once.
Now, if a yum repository wanted to mirror the entire repository on one single torrent, that might be worthwhile... mirror the repository into your yum cache with bittorrent, then use yum to install the RPMs that you want...