Interesting conjecture. But I just ran some numerical tests that make me believe even more in my original intuition. Fixing all the other parameters with r=q=0, I took larger and larger [$]\eta[$]. For all test cases, I found negative theta. Indeed, it looks like, as [$]\eta \rightarrow \infty[$],
[$]C - (S - K)^+ \sim \frac{f_1}{\eta}[$] and [$]C_t \sim -\frac{f_2}{\eta}[$],
where [$]f_1[$] and [$]f_2[$] are positive functions independent of [$]\eta[$].
I tried various moneynesses and rho, and Feller ratios as small as 0.00005 ([$]\eta = 200[$]).
Let me do some more investigation and check my computation. One scenarios that may worth trying is [$]\eta=0[$], large [$]\lambda[$] mean reversion, low [$]\bar v[$] variance at infinity, varying time to maturity [$]T-t[$]. The idea is to make [$]\lambda(v-\bar v)\frac{\partial C}{\partial v}>-\frac12vS^2\frac{\partial^2 C}{\partial S^2}>0[$].
A few numerical checks suggest that last idea isn't going to work either. Also, if [$]\eta = 0[$], all s.v. models reduce to a deterministic volatility model with some non-negative [$]\sigma^2(t)[$]. But then the theta will reduce to the Black-Scholes theta (with r=q=0) times an extra [$]\partial/\partial t[$] of [$]U(t,T) \equiv \int_t^T \sigma^2(s) \, ds[$]. But since [$]U_t = -\sigma^2(t) \le 0[$], all these theta's will have the same sign (negative), regardless of the specifics of the s.v. V-drift.
To check this case numerically, I suggest the OptionCity calculator using the [$]\xi-[$] series with [$]\xi = 0[$] (my symbol for the vol-of-vol). The results there should be exact (the other methods will fail), and it is likely easier than trying to take a degenerate case of the Heston model formula. (Or you can just use the B-S formula with the equivalent deterministic vol).
Finally, thinking some more about what can be proved. Doesn't the absence of calendar spread arbitrage (Gatheral and Jacquier, or here) imply that (for r=q=0), [$]C_T \ge 0[$] in
any arbitrage-free model, where T is the maturity date? If so, then this means [$]C_t \le 0[$] for
any time-homogeneous model, where t is the time. So there's nothing special about these results for Heston. Now, you said earlier you had found a positive [$]C_t[$] in a non-time-homogeneous model, so we don't have a contradiction there. But, the no-arbitrage result suggests it will be futile to seek a positive theta (with r=q=0) in any time-homogeneous setup. Pretty sure that resolves the thread title issue.