Not quite. Vent holes need to be at tge positive end. If the tube id tight around the battery gasses will have a hard problem getting out vent holes.I think that's a little paranoid... you have a much better chance of getting trampled by a cow than having a battery vent in a regulated mod, tootling away at sub-20W. Even if the battery is pointing up and the vent holes of the mod are at the bottom, they're gases... they will go out the vent holes in the bottom.
Pico id about the ONLY mod that puts tge venty holes where they belong.
Is a battery likely to vent in a regulated mod is not likely but i feel bettee with vent holes in the right place just in case.