He's supposedly her best friend, and he let her think that he was dead. That has to be one of the worst possible things anyone can do to a friend.
If he wasn't really dead, then yes, this would certainly apply. But as far as he was concerned he
was dead. Until he comes to the realization/decision to change that, I don't think the argument is valid.
If he'd been lost in a small-plane crash and presumed dead no-one (including Lois) would be angry with him if he suddenly showed up a month later, having finally managed to hike his way back down out of the Rocky Mountains.
Just because he wasn't
physically trapped by these circumstances (like a human would have been in the event of a plane crash)
does not invalidate the fact that he
was trapped and needed time to start to work his way free again.