That behaviour will be database-specific, most databases I've seen simply say that the order is undefined if there is no explicit "order by" clause.
Imagine a query like "select top 10 * from foo where bar = 1", when there is no index on the bar column. The database will need to scan through the foo table, the check the bar column for each item, then return the first 10 that it finds. So it could behave as you describe, just scanning from the top to the bottom in on-disk order, returning results in that order.
However, the database may maintain statistics of how often bar is set to 1, and if it is only sparsely set, it could recognise that a single-threaded top-to-bottom scan would be quite slow. In this case, it could be much faster to break the table up, one chunk per thread, scan each chunk, then return results as soon as enough are found. The final order of results (if there is no order by clause) could then depend on the order that the threads run in, but you'd only see that if there was a lot of data in the table to start with.
https://docs.microsoft.com/en-us/sql/t-sql/queries/top-trans...
This is why it is very common to see suggestions to always specify an explicit order when implementing pagination, as the order of results could change from one page to another if the sort order is left undefined, leading to missing or duplicated results from a user's perspective.