To have the first element, you have to describe a relation of order. It's not ordered by default.
Even now, the default behavior of SQLite is still "undefined" if a Select column doesn't appear in Group By. Well, to be precise it's a single "arbitrary chosen row" used to sort the results. https://www.sqlite.org/lang_select.html#resultset
I'm not bagging on SQLite here (I love it!), but I am bagging on SQL 'cuz EVERY implementation must make far too many of these sorts of Faustian bargains.
It's perfectly possible to do `SELECT * FROM blah LIMIT 1`, after all.