In an out-of-door environment, it is unlikely, with an on-camera flash or speedlight aimed directly upward, that any usable or detectable light would strike the subject.
If, however, the good professor was not observant and did not notice if perhaps the "offending" photographer had a small retractable or removable fill card in place which would have redirected a bit of light forward to provide a "wink" of fill. Could be!
Another guess- Some photographers employ "partial bounce" for fill in out of door situations. If that were the case the flash unit would have been tilted upward at about 45 degrees. This would provide a fill source from the "feather" edge of the beam. If one does not look carefully it may have seemed that the flash was aimed straight up.
Guess # 3- Some flash units have removable reflectors which enable bare bulb operation in hic case a goodly quantity of light would strike the subject.
OR? Sometimes when I am shooting out of doors I decide to do a shot with flash fill and one without. To save time, I would just flip the speedlight upward for the non-filled exposure.
When working indoors, most bounce methods depend on light reflecting off walls and ceilings. Even walls that are not in close proximity to the subject or vaulted ceilings could make any attempted bounce technique less than effective. Many light modifiers are kinda "built in" bounce surfaces or diffusion devices or combinations of both.
I don't know what point the teacher wanted to make besides the fact that bouncing light off the "sky" won't work. Anyway, it's not nice to make fun of novice photographers making rookie mistakes or misinterpreting what they may have heard about indirect lighting.
Oh- this is far fetched but maybe the photographer had a radio-triggered off camera flash in play and was just using his his on-camera unit for triggering. I do that!
It's not uncommon, when attending a night baseball game or a concert under the stars, to see folks trying to illuminate a stadium with a little speedlight- in the olden days, they used "flashcubes".
Come on y'all give a guy the benefit of the doubt!