I've been playing War Thunder for a while, and this happens from time to time. Has it ever happened in real life?
There is such an incident vaguely described at the end of 'Doorknob Five-Two' (memoir of a P-38 pilot) involving a FW-190 that was on final approach landing at an American airfield to surrender. It isn't entirely clear how/if this actually happened.
Without getting into a discussion about gun elevations and visibility, I would say this would have been extremely unlikely in combat.