95 is usually an unbeatable number. However if GTA5 is as gigantically overrated as GTA4 was that could take the Metacritic #1 spot, undeserved.
I don't think any of the other games this will reach that high.
For me personally though, while The Last of Us is very good (only played a little over an hour of it, but still), no game has any chance, because there's a new Zelda on the way! That wins by default .