No.

The GPS can be disabled on a modern smartphone. (At least Android. I have no idea what Apple prevents you from doing...but it wouldn't surprise me. Apple doesn't think you should be able to make any decisions yourself)

In fact, cell phones present a HUGE problem to 911 emergency responders because they can't always figure out where you are based on your phone number. In the old days you called 911 from your house and the dispatchers were tied in with the phone company and got immediate data on where your house was based on your phone number. So you could call from any phone, house, office, pay phone, etc and the 911 center knew exactly where you were.

Now with cell phones they don't have that. There are huge expensive systems that tie into the cell phone provider networks that tell the 911 call center what cell tower you are on. And that's just to make sure the call gets directed to the correct 911 call center. For example I live within 5 miles of 3 different 911 centers. (2 different countries and 1 city. All have different 911 call centers and dispatchers. So I am often connected to cell towers in 2 different 911 jurisdictions) When I call 911 my call is first routed to a fancy computer system that ties into the big 4 networks and determines which 911 call center my call should route to. And even then it's kind of a guess since I could easily be connected to cell towers in 2 different 911 jurisdictions at the same time.

But that's it. That guess is the best high powered computer systems can do as of today in 2017

If your exact GPS location was available at all times, 911 call centers wouldn't have to worry about any of that. You could call from the middle of a forest while hiding under a rock and they could send a fire truck right to you. But they can't.

You can also be sure that GPS location services are disabled because the phone performance is different with it disabled. GPS is a battery and processor hog. If it's running constantly the phone will get warm and the battery will run down faster. The difference in performance is noticeable with and without GPS being active. Even if you leave location services turned on the GPS isn't constantly running unless an app (including Google services) are accessing your location. (To be fair, Google services never stops polling the location service for your exact position. So it's hard to shut it up. But it can be done.)

Another reason you can be sure that GPS can be fully disabled is that Google gives you options for location services. You can go GPS which is hyper accurate but battery intensive. Or you can get a less accurate location by letting Google scan available wifi signals to figure out where you might be. Since Google knows where every Wifi signal is (as long as it broadcasts it's SSID) if knows that you must be within a few hundred feet of a known location if your phone is picking up that wifi signal. (Creepy, huh?) As of Android 7 they can do that with known Bluetooth signals too.

But Google makes it worse! Google likes to run that wifi and bluetooth scanning capability to determine your location IN THE BACKGROUND! So even if you turn wifi and bluetooth off, Android runs both anyway in a lower power mode (as a receiver only, not a broadcaster) to keep tabs on your location. You have to disabled that in a deeper level of settings that's not easily found or known about. (Settings -> location -> 3 dots sub menu usually in the upper right corner -> scanning -> disable wifi and bt scanning)

But wait...it's EVEN WORSE! If you let Google Maps or anything else that used Google Location Services have access to your location, Android turns those passive wifi and bt scanning options back on! And doesn't disable them when you disable location services from the main menu. You can to go back into the deep settings to manually disable those again.

Anyway...the point is...Android has to do all those alternate less accurate location finding options because the GPS on your phone is NOT always running and CAN be easily disabled.

If you do disable those passive scanning options, the cell towers are the best way to figure out where you are. And those are significantly less accurate.