Depends on how you meant by easily. Taking the phone to the beach for example or anywhere with sand is a recipe for scratched since silica (which sand is made of) is harder than Gorilla Glass.
For reference on hardness (Moh's scale) :
Steel (like in keys) is 5
Glass is 5.5
Gorilla Glass is 6.5
Silica is 8
Sappjire is 9
Diamond is 10
And then you have to account for pressure. Given enough force, the softer steel can scratch Gorilla Glass.