No, because the functionality is the same. Just because a test may be so brittle that it breaks the test does not change the meaning (it just may mean you have to manually inspect the now failing test).

The point is that most patch upgrades can just be run through a test suite and accepted. That may still lead to breakages, something that seemed minor and non-breaking to the developer could instead be breaking for a given user, but the point of semver is to convey actionable meaning and intent, which it does.