I saw a slight change in this behaviour this morning. I don't know whether it's a one-off, or a result of an update (I'm on Win11Pro, 23H2).
While using Excel with a File Explorer window minimised, the Excel window unexpectedly vanished and the File Explorer window opened instead. After about a second, the File Explorer minimsed again and Excel reappeared. I am confident that this was not a result of anything I did - I was reading something at the time and not using the keyboard or mouse.
And - having said all that - File Explorer has just grabbed focus yet again, in the middle of me typing this post, and it did not minimise itself afterwards. So maybe this morning's episode with Excel was just a one-off.