Dragon Commander won't - as far as I can see/interpret it - have no levelling, therefore it won't be an RPG, imo.
It will, on the other hand, have dialogue where you will be able to adopt a certain personality that hasn't been completely defined for you, and which will have impact on how the game and possibly story develop.
You'll get the opportunity to, dare I say it, play a role.
That said, RPG has become a very nebulous term. Modern Castlevania games have levelling up of all kinds, but I wouldn't call them RPGs.
