Agree. Even at his beat Comedian didn't showed anything really decent besides murdering helpless people and almost raping a woman which he caught off-guard.
Watchmen fans would agrue like: "Comedian defeated Ozymandias, who easily wiped the floor with Rorshach and Nite Owl, and both of them can one-shot thugs and Rorshach can take out several cops with ease".
Yes, so? Ozymandias was actually studying Comedian's fighting style and let him win. Rorschash and Nite Owl are also not that impressive in comparison to Punisher.
One-shotting a fodder isn't really impressive feat, and Rorschach taking out several cops may sounds cool, but he eventually was outnumbered and subdued. Frank, in the other hand, defeated 4 armed cops while handcuffed behind his back and escaped from a police aircaft.