Yeah, the outdoor survivors are in a situation where the excess moisture can drain away from them and/or be soaked up by absorbent soil. I would think the first frost likely cause the wet part of the fruit to burst and removes some of the 'deathtrap' effect on the seeds. Still you may rarely see 100% germination of volunteers from a tomato - only the lucky, which managed to be dry enough to freeze safely, or managed to be in a warm pocket of soil where they weren't frozen solid, can survive.
For a seed in a fruit in a bag in the freezer, there's zero chance to get lucky. But if anyone has doubts, please experiment and share your results!
