Is "Comedy" a videogame genre?

No, comedy is not a video game genre.
A game can be comedic, but there's no such thing as a game where the comedy is the main game mechanic.
You can have stuff like Day of the Tentacle, which is comedic, but is a point and click game. Or Earthbound, which is comedic, but is an RPG. Etc.

adventure games were the closet thing seeing they had non-existent gameplay and were basically just cartoons

By your view that would mean comedy books are just joke books and comedy films are just taped stand up comic routines. Comedy books and movies have actually stories, characters, conflict, and action ALONG with a lot of jokes.

Saints Row The Third would be a good example, no game tries to be a "comedy only" game because comedy isn't really a genre.

>>383985115
Wait, what about Horror? That's very clearly a genre of game, yet there aren't any game mechanics that tie specifically to Horror and nothing else.

There are totally games where the mechanics are designed for comedy. Surgeon Simulator, Jazzpunk... I can't think of a lot of examples actually but I think this is a real thing.

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well video games are mostly catagorized by their prime distinction, which is gameplay styles, i.e. how player interacts with the games. Comedic is more like a tone as >>383985115 pointed out.
even an RTS can be comedic if the animations, world building and flavor texts are fun.

>>383985250
this and yeah, old lucas arts point&clicks like escape from monkey island or sam&max were clearly "comedy", contrary to other point&clicks like myst that were essentialy "reflexion".

I think any games which's purpose is to make you laugh, not just to smile or ease the pressure, is a "comedy" game.
Borderlands 2, serious sam, duke nukem are "comedic" FPS, because they clearly want to make you laugh.
On the other hand, battlefield or farcry are not comedic FPS, even if they have some funny moments

>>383985320
Sure there are. Amnesia and SOMA fuck up your character's vision if you look directly at the monster. In Eternal Darkness if you didn't keep your Sanity up then the game would fake you out with intentional glitches.

I'd call it a subgenre, just like horror or drama. Even if a game's main goal is to scare you, the genre is still going to be the mechanics it uses to do so. Is it survival horror? a scary VN?