With respect to SQLite, this method does not always return the correct result. This applies to errors including SQLITE_FULL, SQLITE_IOERR, SQLITE_NOMEM, SQLITE_BUSY, and SQLITE_INTERRUPT. According to the documentation, these errors can cause an automatic rollback. The method does not take this into account (because it uses PDO's internal tracking mechanism).
However, SQLite has a way to find out whether the transaction was automatically rolled back or not. By using sqlite3_get_autocommit() C-language function.