It depends on the filesystem.
The vast majority of filesystems will allow a file of zero length to be created even if there are no free block on the disc as no blocks need to be allocated at that point, unless the directory entry's blocks are full in which case you will get a "no space" error as it tries to add a new block to the directory listing. Certainly NTFS will works way. Some filesystems allow the content of small files to be stored in the the directory entry itself or other pre-allocated structures - so you might be able to create small-but-not-zero-length file on a seemingly full filesystem.
Some older filesystems (FAT*?) will always allocate the first block of the file at creation time as their spec doesn't allow for files with no blocks allocated so these will always fail to create a file on a full device.