By no means do I consider Matt Cutts's word as being sacred. But here is a Youtube video where he talks about this concept a bit. I can't post a URL so search for "matt cutts hidden text" on Youtube. The video is called "Hidden text and/or keyword stuffing" posted in 2013.
In today's latest iteration of Google's sophistication, it might be safe to assume that content cloaking is far more detectable. Google parsing through CSS to test for matching font and background colors or layered elements with text being covered is more than likely happening.
Just a few short 5-7 years back, it was widely accepted that Google couldn't read/couldn't understand/and ignored JavaScript entirely. As of 2011 Matt Cutts confirmed "Google is now able to execute AJAX/JS to index some dynamic comments." That was 3 years ago!
All things being equal, it would seem if a Google bot is sophisticated enough to run JS, it can do some rudimentary test to determine content cloaking.