When you call RVM from cron (or a Makefile, I would expect) it's important to set up the right environment. The Scout team have a great blog article explaining this:
http://blog.scoutapp.com/articles/2010/09/07/rvm-and-cron-in-production
The important part is ensuring you have a full login shell so you have access to RVM.
/bin/bash -l -c 'the_command_inside_makefile"