Well, according to the legend, by Ovid, she most likely is. She is described as a fair haired maiden, which results Poseidon forcim himself upon her in the temple of Pallas Athene, and therefore Athene punished Medusa by making her hair venomous snakes, and her gaze to turn people to stone.
She was genuinely a victim, and had all the reason for defending heeself, while probably being more kind than any other character mentioned in association with her. Hell, the reason she was killed was that some dude didn't have a horse to give to another dude, so he sent his son to get medusas help. And then that kid had divine aid for killing Medusa, who up to this point has been nothing but a victim for the entertainment of gods.