OP, I'd say 'no'.
I know with my mower, the top of deck is higher than the bottom of engine
A Drain Plug would not be particle / I drain oil from the 'fill' tube.
One thing to watch out for:
When ever I tip my push-mower on its side to change the oil, the Air Filter Housing ends up with oil in it.
If this happens to you, my advise is to 'remove' the Air-Filter BEFORE draining oil.
Also helps when tipping mower is to have Gas Tank near empty.