I've had this happen once for sure over the past forty years as I recall.
This was with the '99 Accord LX sedan we had way back when ($16.8K brand new, 5spd VTEC, totaled by a son who fell asleep and ran it into the back of a rig at around 175K while on his way home from a late turn at work. Airbags deployed, Accord was toast and son was fine, thankfully).
I had no idea why there was oil leaking out around the filter base, so I just cranked the filter tighter until it stopped.
This had the effect of cutting and forcing out the retained gasket, as I discovered at the next drain.
Made it a habit ever since to ensure that the base gasket came off with the removed filter.