i think you can on a cyclindrical surface, but not on any generally curved surface ... three points define a plane , the 4th is constrained to the modelled surface and will almost always be off the plane and so it warps the elements ... but this should be controlable to be within the element's tolerance.
i'd be surprised if a solver failed "just" because the elements were slightly warped. usually the problem is that the solver doesn't fail even when the elements are excessively warped.