Nope, because phones don't have altitude detection. The only thing it can go by is accelerometer data, and you can infer what that data should look like using high school physics. They probably measure the duration of "weightlessness" (freefall), and maybe also check that there are large enough spikes of acceleration at beginning and end, although those will be mostly outside the range of the accelerometer. You can probably fool it by throwing it from some high point (bridge, building) and have someone catch it at the bottom.