Yes, except this is not what people talk about when they say code is the documentation. What's meant in that context is no documentation and only code, with the idea that you can always read the code if you need to figure something out. Which, of course, is nonsense.
Nah, that's your own (incorrect) interpretation, the first result of googling 'code as documentation' [0], starts off with:
> Almost immediately I feel the need to rebut a common misunderstanding. Such a principle is not saying that code is the only documentation.