(Some Android phones are secure, but many are not. A lot don't even encrypt data. So it depends entirely on the phone, but it's likely the FBI would have had an easier time getting in than they have with the iPhone.)
Really depends on the owner of the android. Mine is encrypted with a finger print scanner and back up password that if wrong too many times erases all data on the phone
...because the FBI would have already been in.
http://www.cnbc.com/2016/02/18/what-if-the-fbi-were-dealing-with-an-android.html
http://recode.net/2016/02/21/what-if-san-bernardino-suspect-had-used-an-android-instead-of-an-iphone/
(Some Android phones are secure, but many are not. A lot don't even encrypt data. So it depends entirely on the phone, but it's likely the FBI would have had an easier time getting in than they have with the iPhone.)