The short answer to your question is: sure! One of the missions of Spring's persistence/ORM support is portability, meaning it helps to decouple your selected persistence framework, making a transition to a different strategy far simpler. To help support this portability, Spring provides a generic exception hierarchy (allowing you to handle exceptional conditions without being tied to a persistence framework's classes), a generic transaction strategy, and a consistent approach for querying, batching, updating, etc.
Of course, when you are talking about moving from Hibernate to JPA, the transition is much simpler since these two technologies are very much related. In fact, we discuss JPA in our book, along with the question of when it makes sense to use JPA and when it is better to use Hibernate. We typically recommend the JPA annotations, whenever possible, but some of these "rules" are a bit application-specific.
Thanks for your question, and I look forward to hearing from you soon.
Paul Tepper Fisher, author Spring Persistence with Hibernate
I think that this rarely happens, but it might happen during development, when it has been decided that an application should finally use common specifications instead of proprietary frameworks. I've never seen such a change though.