Unless they mean it humorously, when people utter this phrase – “but I’m not complaining” – they are *always* complaining; i.e., they are expressing “pain, grief, or discontent.” What these sad and/or irritated individuals mean to say is this: “But I’m not whining.” That is, they are not complaining in a petulant, feeble, long-lasting, or high-pitched manner. Nonetheless, they *are* whining, usually, despite their protests of innocence, aren’t they?
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To me the words “I’m not whining” don’t speak for themselves (them self?). Too many variables… the source, the subject, the body language, tone of voice, etc. I always try to draw a distinction between “critical perspective” and negativity, and other similar ideas.
A person could start a sentence “I’m not whining” and yet finish with a clear, unbiased observation or critique.
That said, most of the time, you’re right.
If the pitch of the voice saying “I’m not whining” is higher than normal, it’s whining.
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Really depends on context.
“Fred’s whining, but I’m not whining.”
They’re not whining.
But I agree that if they say,
“it makes me both sad and angry, like a starving inarticulate child, that Billy doesn’t want what I want out of our relationship, but I’m not whining”
Then they’re dumb as hell.