There is
always a diode (one of two body diodes) between the drain and source of
every mosfet. There is another body diode between the source and the substrate (body), but it is normally short-circuited by an internal mosfet connection between the source and the substrate, a connection that is necessary to properly bias the conduction channel with the gate-to-source potential.
So, all that said, every diode has a reverse breakdown characteristic that falls somewhere between zener conduction and avalanche conduction, depending on diode construction. It is not uncommon to represent this fact by showing the body diode as a
zener diode, perhaps to emphasize that there is a specified breakdown voltage limit on the drain-to-source voltage, V
DS, but the important thing to realize is that this diode is
never intended to operate in a reverse breakdown condition. Most, if not all, datasheets
fail to specify the conditions under which it is safe to operate the body diode as a zener diode, although some will specify how much (pulsed) energy it can dissipate without failure, as mentioned by
@duke37 in his post #2. Best to avoid pushing device limits if you want long and continued operation from your mosfet.