I needed to use this to touch the /etc/cron.d directory when I updated some files in there. I know the docs say this isn't necessary, but I'm finding that i need to do it in order form my changes to be picked up quickly.
I ran into the permissions error as well and I found that using chmod 777 /etc/cron.d does the trick.
So, you should be able to use the PHP touch function on a directory that has open write access.
Of course, this isn't the most secure approach, but in our application it's not a big deal for that folder to not be super secure.
