I don't know for a fact, considering in all my years dealing with various vets for my dogs none has ever mentioned such a concept, but I suppose it's entirely possible. One thing that can lead to GERD is overeating which puts pressure on the stomach's hiatal/esophageal sphincter, causing it to be stretched over time so that it can't hold in the acids any more. Seems to me like a dog who regularly overeats could have the same effect and GERD symptom. Also, some medications can cause stomach upset and heartburn; for a while one of my dogs was on a medication that had that side effect, so I had to also give her omeprazole (Prilosec), which is used to treat GERD. However, since that was an acute symptom due to medication rather than something chronic, I don't think it would qualify as actual GERD.
Remember, when in doubt or when you have any questions about your pet's medical health, it's always best to ask the vet.