I don't know if it has. However it is reasonable tactic. If you have a recording of them agreeing to something that is strong evidence in court. You need to figure out how to get payment, but if you have bank information from some other source (not hard) a charity to "help the poor" that spends 5% on the poor and the rest on CEO isn't hard to set up.
Has that ever happened?
Does a fake recording like that make it easier to scam you in any meaningful way?