If you mean that those requests were not made at all, then it's unlikely, as this is trivial to check: repoint DNS directly to your server and watch. CF seems to care about their reputation, so I don't think they would do something that is so simple to disprove.
If you mean that those requests were actually "good" (real humans) but CF mistakenly mark them as bad... then yes, this probably happens. For example, I have old tablet which regularly gets CF captcha, and sometimes this causes me to abandon some websites rather than solve it. I am sure that this appears in the logs as "bad" request -- after all, how can you tell frustrated human from defeated bot/DDOS?
But for many sites, the question is not "captcha vs same content no captcha" but rather "captcha vs significantly reduced functionality"... so at least for me, occasional captcha is worth not having to login / having full-resolution images etc...