Robustness of the Luttinger theorem for fermionic liquids is examined in holography. The statement of the Luttinger theorem, the equality between the fermion charge density and the volume enclosed by the Fermi surface, can be mapped to a Gauss's law in the gravity dual, a la Sachdev. We show that various deformations in the gravity dual, such as inclusion of magnetic fields, a parity-violating θ-term, dilatonic deformations, and higher-derivative corrections, do not violate the holographic derivation of the Luttinger theorem, as long as the theory is in a confining phase. Therefore a robustness of the theorem is found for strongly correlated fermions coupled with strongly coupled sectors which admit gravity duals. On the other hand, in the deconfined phase, we also show that the deficit appearing in the Luttinger theorem is again universal. It measures a total deficit which measures the charge of the deconfined ("fractionalized") fermions, independent of the deformation parameters.