The same rule applies to a virtualised environment. Of course, in a SAN-based environment disk performance should outperform single spindles by an order of magnitude, so you can just place it on a different virtual disk (or, if you really insist, even on a different virtual disk on a different LUN), but this does not negate the reason for Microsoft's recommendation.
Windows Domain Dontrollers disable OS-based write caching on the volume containing the AD database. Therefore, if you store the AD database on the same volume as other data (say, your OS), you will take a performance hit.
For this reason, it is still a good practice to store the AD database on a separate volume. For the purposes of virtualisation, this volume can be just a separate virtual disk. (Note: placing it on a separate partition on the same virtual disk will not help.)