One can interpret certain suttas as showing the Vipassana noting technique, but it's not explicitly pointed out in an instructional way, so it's hard to say if it's not a later interpretation of the text used to justify a newer practice that developed in Burma and Sri Lanka.

The explanation Goenka gives is that the technique of noting was passed down from teacher to teacher all the way back to the Buddha, but of course every tradition says this about every technique so it can be hard to verify.