Well yes, but think about it. For the close to fail, rather than a preceding write, then you would have to be wanting to write just less than one buffer-full (512b/4kb/whatever), more than the filesystem could accomodate.

You program would have to write enough data so that it filled the last block on disk, and then just a little bit more before deciding to stop writing and close the file. A few bytes less and no error occurs because the file is successfully written. A few bytes more and you (should) never make it to the close because the write/print will have failed. That's a pretty small window of opportunity. And that's the simple case.

Most filesystems do caching outside of the auspices of the C-runtime cache, which means that you'd likely successfully close the file, flushing the last few bytes to OS cache, and the failure wouldn't occur until sometime after, possibly long after your process has terminated. In the meantime, some other process may delete or truncate a file, or the OS terminates a swapped out processes and frees a lump of disk space. A million things.

The mounted filesystem case is somewhat different, but again, the odds that the filesystem would go away at exactly the moment between your having successfully written the last buffer load (to cache), and deciding to close that file when the flushing of that last buffer would fail, are really very slim.

The really interesting question is what do you do about it when you detect this situation? At that point, unless you are lucky enough to be running on a system with multiple disks, even trying to log the failure is likely to encounter the same full disk scenario. You could also think about re-tries in the hope that some other process might have free'd some space up. Or you could trying deleting temp files etc. But in the end, if the scenario happens, there is unlikely to be a good recovery strategy.