Yep, they're called bottle krausens. I think they happen more than we think, but a lot of brewers, like myself usually just stick our bottles in a dark place and not look at them while they carb.
But carbing is just another fermentation in a mini fermenter, and since you usually get krausens during fermentation, it's not too surprising that we see bottle krausens but most of the time they are gone in a few hours.