I get your urge to support the "Apple Team" at any cost - but seriously, this is a SMC update, not an MAC OS X update as you boldly state. If you understand computers - it is a firmware update. Firmware is at lower level than OSes - fixes at firmware level affect all OSes - Mac, Linux, Windows etc. Battery charging issues for example that were fixed few days ago.
So yeah Apple must have a way to install those that is not dependent on OS - my HP Workstation BIOS can connect to HP Servers and get the BIOS updates without any OS requirement for example. Apple's firmware already connects to Internet to download recoveries etc. so it's not far fetched.