JohnMu from Google posted in a Google Webmaster Help thread that Google typically crawls a site's robots.txt file on a daily basis. This is the first time (at least that I can remember) I have seen a Googler make a statement on the crawl frequency of robots.txt files.
JohnMu said:
We usually only check the robots.txt file once a day for most sites, so I assume you were just still seeing the version that we fetched yesterday.
I have not validated this with my sites log files, but that is not the point. The point is a Googler said, on a general level, how often Googlebot will refetch a site's robots.txt file.
Forum discussion at Google Webmaster Help.

Comments:
Michael Martinez
09/03/2009 05:11 pm
What would happen if you put this entry into your robots.txt file? User-agent: * Disallow: /robots.txt
Ruud Kok
09/04/2009 07:27 am
So, will this mean that if you put a new folder online, which you don't want to be crawled, you need to put this folder into your robots.txt about 24 hours upfront?