If the photo cell was on during the short circuit then the
chances of damage to the photo cell are at a minimum. If the short
circuit occurred when the photo cell was operated then yes damage
to the internal contacts of the photo cell could have happened.
What happens is, the short circuit is downstream from the photo
cell and when the contacts of the relay close in the photo cell the
dead short is applied to the contact faces of the relay. This is
somewhat like striking an arc with a welded with the same results,
the contact faces weld close and the circuits breaker trips to open
the short circuit. With the pole faces of the photo cell's relay
closed it gives the illusion that the photo cell is not operating.
The photo cell's circuitry will be working but the relay will not
drop the circuit open because of the welded contact in the
relay.