Well, no. Voltage is only one part of power usage, higher clocked cards use more current than lower clocked cards at the same voltage. That's why overclocked cards get hotter even when not overvolted.
No, he's right, when taking the whole computer into the power efficiency picture. 10% more core frequency = 10% more power used (and generally mhash scales linearly with core speed), but the system has a baseline watts, so do some math with some assumed numbers...
100w baseline, 1000w used from video cards doing 2000 mhash. 1.8181 mhash/watt.
Increase core speed by 10% without increasing volts, system is now at...
100w baseline, 1100w used from video cards doing 2200mhash. 1.8333 mhash/watt.