Yes it can depending on the Amps that your charger can put out. I also never understood the issue with cell # 4 either. Did you get them to 3.65 volts? Unless you did there is now way to determine which of the two possibilities that I and others were saying.
@electric makes a good point, the bottom balance in the first place maybe why you were seeing one cell high. That cell may be slightly less capacity but it is not worth worrying until you know how much or test the other 3 cells. At this point, as I suggested earlier, put them in the pack and log the results. Also, just so everyone is on the same page, let us know if you charged them in parallel to 3.65 volts or if you quit before then.