It may appear that the plane went through the ground, but in fact it did not. At least on the opponents computer. I haven't seen the film yet. But I can tell you this. If the last update showed him pointing down doing 300mph and didn't update for 4 sec, for those 4seconds without updates, your computer will continue to show his plane going in the same direction at the same speed. Then when you saw his plane pull out of the ground, that was because the next update had his plane at a different spot in the air, going in a different direction at a different speed. So instead of seeing his plane teleport to that next position, your computer will show his plane warp to that position.
Besides, I think HTC has it so that the closer you are to the other plane, the more updates you will receive. More effecient that way. So the closer you are to the enemy, the more updates you'll need to not notice the warps.