Yes, an act can be empathetic even if the person doing it doesn't feel empathy. For example, smiling at another person is an empathetic act. Sociopaths do this all the time without feeling actual empathy for people. It makes it easier for them to blend in if they seem to have empathy via empathetic acts however disingenuous they may be.
-- to nitpick -- empathy is the ability to put yourself in someones position & truly feel what their reality must be like -- compassion is acting on that empathy --
It doesn't actually require having empathy to commit empathetic acts which are acts that display empathy. For example, smiling is an empathetic act, but it doesn't require having any actual empathy to do it. Sociopaths can smile and commit other empathetic acts to appear to have empathy without having any true empathy behind it.
