Cluster, as in a clustered sample survey? Or, cluster, as in a feature of the data? Though I'm not sure that it matters.
One can easily construct a data set in which the SE for the naive estimator (e.g. un-clustered) is greater than that for the adjusted estimator.
In general, model based adjustment reduces the error term. That's one of the main reasons for modeling. Occasionally, it can increase the error term; that may be because a (some) predictor(s) are not related to the outcome. It can also happen if the model has the wrong functional form.
An exhaustive answer to your question is the subject for a book.