absolutely not. when PLL intends for someone to actually be dead they show the body.
showing a fake tattoo and a helmet and not bothering to show who it was pretty much proved he was alive from the get go. the intent was only to make spencer think he was dead, not the audience.
they also wouldnt be able to produce that kind of story change. the episodes are all filmed way before they actually air, so the fans could not react and say 'wahhhh poor toby' in time for them to change it. the network sometimes gets involved though, but they would have gotten involved at the script reading point not after it already happened.
i like to think he was intended to die in season 4. Spencer would have had her dark arc being -A and realizing that losing her friends wasnt worth having toby, and she would have ended up killing him in the 4A or 4B finale to save the girls.
*when life gives you lemons*
Sara: are you a sour lemon?
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