if you are going to do it, you might as well do it right.
a true red reflex exists when the patient and the examiner's eyes are coaxial, such as with a direct ophthalmoscope. there are some conditions in which light rays exit the patients eyes in a divergent manner, such as very high hyperopia or large intraocular tumors, and a good penlight exam would pick this up.
but using the direct ophthalmoscope will be faster (assuming you have one) and you will be more confident in declaring a postitive or negative finding. and your friendly ophtho colleagues like myself will love you for it.