It's certainly a base for data and can be used to implement all core concepts of relational calculus but it isn't designed for such and doesn't do so with performance in mind. Conversely, filesystems are often implemented using B-trees as many RDBMSes are but aren't designed for many of the operations one might typically ascribe to a database.

Nomenclature is tricky... how does that saying about the two hardest problems in CS go again?