TSLA most certainly could have tracked it just using the GPS and woken the car (or even bricked it) remotely. Superchargers may have been used, but definitely weren't needed to track this vehicle.
From the article: "Since this person disabled GPS tracking on the car, the owner had to utilize a different method of tracking down the alleged crook."
I don't own a Tesla, but this implies it's possible to turn the GPS off.
I don't own a Tesla, but this implies it's possible to turn the GPS off.