TOA(time-of-arrival) and TDOA(time-difference-of-arrival) positioning techniques are commonly used in many radio-navigation systems. From the literature, it is known that the position estimate and error covariance matrix of TDOA obtained by GN(Gauss-Newton) method is exactly the same as that of TOA when the error source of the range measurement is only an IID white Gaussian noise. In case of geo-location and indoor positioning, however, multi-path or NLOS(non-line-of-sight) error is frequently appeared in range measurements. Though its occurrence is random, the multipath acts like a bias for a stationary user if it occurs. This paper presents the comparisons of error characteristics between TOA and TDOA positioning in presence of multi-path or NLOS error. It is analytically shown that the position estimate of TDOA is exactly the same as that of TOA even when bias errors are included in range measurements with different magnitudes. By computer simulation, position estimation error and error distribution are analyzed in presence of range bias errors.