First, there are never any guarantees; there are only best practices and lessons learned that help us work safer and that help make our installations safer for the users.
Secondly, planet Earth is not a player in the task of protection under short circuit conditions. If current does manage to find its way from a panelboard into the dirt (perhaps, for example, by way of a hot wire that touches a metal wall), and from there back to the source (via the grounding electrode system), the resistance of that fault path is going to be high enough to keep the fault current low enough so that it is not enough to trip the breaker. Ground rods and similar items are simply not there to assist in short circuit protection.
What, then, are you trying to ask?