I'd say yes, just because it's a submarine with actual guns. However, I'm not sure which version of Surcouf it is, since the artist didn't draw all of Surcouf...
A bit hard to tell whether it's the Surcouf or the fictional I-507 Lorelei submarine from the 'Lorelei: Witch of the Pacific' film, but judging from the lack of a mini submersible dock at the back of that conning tower structure, I can strongly agree it is the original Surcouf.