Klong-chen-pa in his Shing rta chen po, an auto-commentary on the Sems nyid ngal gso (p. 887), states: rtog ge zhes pa’ang gnyis las | sa mtshams kyi rtog ge ni so so skye bo ste mi bden pa phyin ci log tu bden par zhen pas de skad ces bya’o || grub mtha’i rtog ge ni dngos por smra ba’i gzhung thams cad de | gshis la med kyang rnam par sgro ’dogs pa’i phyir ro ||.
Note that the former is identified with persons (gang zag) and the latter with treatises (gzhung). Tibetan authors often do something like this.
One should also compare a passage found in his Yid bzhin mdzod ’grel padma dkar po (p. 650), which seems to provide scriptural sources for the two kinds of rtog ge ba found in his Shing rta chen po, namely, a quotation from the Śatasahasrikā Prajñāpāramitā for the sa mtshams kyi rtog ge ba and a quotation from the Prasannapadā for the grub mtha’i rtog ge ba. I did not check these quotations. In short, according to Klong-chen-pa, those of us who have no direct insight (ye shes: jñāna) or direct cognitive access to the true reality are called (“dogmatists [by pṛthagjana–ārya (skye–’phags)] distinction/divide”) (sa mtshams kyi rtog ge ba), that is, even those bodhisattvas or Mādhyamikas, who have not yet reached the darśanamārga level, would be called as such. As for the “doxographical dogmatists” (grub mtha’i rtog ge ba), they are de facto non-Mādhyamikas, who posit the true existence of some kind of entity, be it of mind or matter or both.
I would like to offer my own interpretation based on the Einsicht–Ansicht distinction: sa mtshams kyi rtog ge bas are “dogmatists devoid of Einsicht (insight)” and grub mtha’i rtog ge ba bas are “dogmatists devoid of correct Ansicht (view).” The two are not coextensive (khyab mnyam). All dogmatists free from correct Ansicht are also those who have no Ensicht, but the reverse is not true.
There is, however, a third popular/common usage of rtog ge ba, that is, in the sense of a (German) “Rechthaber.” That is “someone who is self-opinionated (rechthaberisch) or dogmatic” or “one who is not really interested in knowing the state of affairs but one who is just interested in being ‘right’ or in winning an argument by hook or crook.”