Yes, I think so - except - I'd say "in" rather than "on" more likely. Europa's ocean gives an example - it's kept liquid by the tidal heating effects of the other moons of Jupiter. It has an oxygen rich ocean - and it's oxygen rich because of the magnetosphere of Jupiter and the ionizing radiation splitting the ice into hydrogen and oxygen.
As far as I can see Europa's ocean wouldn't be that much different if Jupiter was orbiting a brown dwarf or even floating through space as a free planet in space, with the same system of moons with same orbital periods.
The energy source in this case is the tidal heating of Europa. Due to its resonances with the other moons which keep it in an eccentric orbit around Jupiter and then the eccentricity tides of Jupiter.
For that matter, there's lots of ionizing radiation closer to the Galactic core which presumably could create oxygen in the oceans by a similar process - if you are in vicinity of a black hole or some such, wouldn't even need to have Jupiter, just any Moon with an internal ocean heated either by tidal heating or residual radioactivity - and you've got a potential for complex life in a sea rich in oxygen.
That's just talking about conventional Earth type life, there are lots of other ideas for unconventional biochemistry and life. Some ideas that have been put forward as serious proposals could exist in temperatures so low the main liquid is liquid nitrogen, and science fiction writers have explored the idea of life at temperatures so low that the only liquid is liquid Helium