During WWII a sailor was killed when his SW victory model discharged after being dropped. SW then added a safety block. That block or an improved version has been used on all models since. If the revolver in question is a military surplus without the block then yes that could happen. But if it is a later model it is more likely someone was doing something they shouldn't have been doing.
The safety block is a long L shaped piece of metal that rides in a groove in the side plate. The short end of the L acts as a block between the hammer face and the frame. When the trigger is pulled back the short end of the L drops down out of the way and lets the hammer face enter the frame completely. There is a possibility that the safety block was removed. During the 80's, it was quite the fad to slick up the trigger pull on smiths by removing the safety block. I was in a gunsmiths shop once and he had a small box full of them. Even with the safety block removed, its is extremely difficult to have the gun land on its hammer and discharge, usually the hammer spur will break off, but the gun does not fire. Over the years I have dropped both a smith and wesson and a colt while hunting and had the hammer spurs break off, but neither discharged. Now if it was a single action revolver like a colt or ruger that scenario is very likely.
By the way the scars on the sideplate show why you should never pry a sideplate off a smith and wesson. The guy had buggered his gun up something fierce doing bubba work on it.
I have added a picture of a sideplate with the groove in it where the safety rides up and down. And I added a photo which shows the safety in place.
Last edited by 1sgpierce; 03-29-2012 at 10:58 PM.
Reason: Added Photo
You didn't mention the brand and type of revolver involved, but odds are it was an old-style single action without a transfer bar (think Colt SAA), which should not be carried with a round under the hammer for this very reason. Load one, skip one, load four, hammer to rest, if I remember correctly.