Strictly speaking, it's true, but when multiple games with the same name are released, it's convention to use the year for the newer one. (It's also generally convention to not use the year for the original one when the newer one is a remake of the older).
So SimCity (2013) would be the most expected way to refer to the game.
I actually clicked on it thinking it meant the original SimCity which I adored, not realizing that was many decades ago, and expecting it to be some interesting argument that SimCity was somehow so good that it proactively ruined every city sim game that would come after it.
And which one launched a decade ago? How about we combine the three bits of info and see what we think we have... name = "SimCity", launch = 2013, reception = disasterous. Only one of those matches the '89 game, so it's clear which one is being referred to.
With the frequency with which older articles are posted to HN, it's easy to imagine this was an older article (re)posted. I'm old enough that I remember the original and SimCity "2000" and had no idea there ever was a 2013 version.
This is my feeling too. The title as it stands without a date clarifying that it was the SimCity from 2013 makes no sense. If I knew there was a 2013 version, it would probably make sense, but before clicking into the article and reading a little, I had no idea. And the only reason I clicked and read was because I thought "surely there's a mistake in this title".