We prove that Nagaoka's theorem, that the ground state of the large-U Hubbard model with exactly one hole is ferromagnetic, holds for any balanced Hamiltonian. We argue that, in itinerant electron systems, a balanced Hamiltonian, rather than bipartite lattice, defines an unfrustrated system. The proof is valid for multiorbital models with arbitrary two-orbital interactions provided that no exchange interactions are antiferromagnetic: a class of models including the Kanomori Hamiltonian.