He very well could be but only once we gain widespread, mainstream adoption which is possibly still some time away. Bitcoin will need to be standing alongside giants like Paypal before something like TIME recognises Satoshis true genius.
Even if he's in top 100 it's fine...so many random people make it on to the top 100 list, who many people haven't hear about. Majority of the people have heard about Bitcoin. We need to make Satoshi popular.