TLDR: Yes, but probably no, well maybe.
Fundamentally, the second law of thermodynamics is about entropy: If you create it, part of the energy budget of a running engine has to be spent on getting rid of it. Combustion processes create entropy as a result of creating heat, and the rest follows.
To the extent that fuel cells (and human cells) avoid creating entropy, they can be more efficient than the Carnot limit. The notional ideal fuel cell reaction: "moleculeA + moleculeB = moleculeC + electricity" doesn't generate any entropy because it's fully reversible (for H/O cells, the reverse reaction is electrolysis). That means that, in theory, it can be fully 100% efficient.
Although there are practical difficulties, people have shown ~90% efficiencies in the biological version of this. (I realize that paper is a bit old and almost off topic, but it shows that biological fuel-cell reactions are intrinsically not combustion-limited)
There are some inherent practicalities, however. Chemistry has a little bit of physics in it, however, and for any particular reaction those might mean that the result is not created at rest, is created in an excited state, or entropy (effectively, heat) is intrinsically created as part of the reaction. That will reduce the efficiency, even before engineering considerations are involved.
This makes it a bit hard to define efficiency unambiguously because when you divide "electricity out" by "energy in", there are several possible choices of "energy in". Practical fuel cells can routinely get very large fractions (over 95%) of the possible electrical energy out, but due to the underlying reaction physics, etc, not all the heat energy of the inputs are available.
For $H_2$ and $O_2$, not counting engineering costs and energy costs of getting them to reaction temperature and pressure, a fuel cell can recover 83% of the possible input ("chemical caloric") energy. The rest becomes heat, and it's then an engineering question if that's also useful ("thermal energy recapture" is the term of art). That number varies a bit with temperature of reaction (higher is better, in general) and some other considerations; I've never looked at the kinetics of a cryogenic $lH_2$ and $lO_2$ fuel cell and there may be some intrinsic thermal losses there.
So then it becomes a matter of engineering: Getting the reactants to the right place at the right temperature and pressure, processing the product water, heat and electricity, etc.
It's going to be really hard, though, to beat the numbers in the question. The "normal" thermal engine already has great 2nd-law conditions to operate in the hot side stays really hot, and the cold side is pretty cold.
So in practice, I think the best you could do is a complex, heavy engine that's just a few percent better. That's not going to be a winner.
What you might find, though, is some other set of reactants that has a better energy-mass ratio. If they don't have to burn hot and quick, there might be more possibilities.