Yes: EAV simply amounts to the equivalence between $\forall x P(x)$ and $\forall yP(y)$.
That is, provided that we avoid "clashing" of variables, the choice of the bound variable does not affect the meaning of a formula.
In the proof above it is needed in order to "free" $y$ prior to "swap" it with $x$.
As you said, we choose a new variable $z$ that does not occur into $Pxy$; thus, for sure it is _substitutable for_ $x$ in $∀x∀yPxy$.