The Wronskian Theorem applies to any 2 functions regardless of whether or not they are solutions to a homogeneous DE.
Plain and simply if the Wronskian is not 0 2 funtions are LI.
Granted it is mainly used in regards to solutions to homogeneous equations but is not restricted to those situations.
It is easy to prove for any 2 functions if they are linearly dependent the Wronskian is 0 and hence the contrapositive I f the Wronskian is not 0 the 2 functions are LI.
In all honesty I've only ever used the Wronskian in DEs.
Most prominent is it's role in solving the non-homogeneous 2d order Eq
in the method of variation of parameters.
Its easy to then associate exclusively the Wronskian to DEs but it is more general.
Having said that you may be thinking of the theorem if f1 and f2 are
solutions to a homogeneous DE and W(f1,f2) is not 0
then the general solution is Af1+Bf2.
which is really a corollary to the more general case.