You don't want heat from the video card and processor to go into the PSU, that's the problem with top mounting.
In the past when PC components didn't generate heat in meaningful amounts, it didn't matter if you top mounted a PSU and used the PSU as a case fan.
Once PC components started generating large amounts of heat, that became a problem.
See, PSUs work much much worse at high temps than they do at low temps and rising heat from components is a big deal. PCs with top mount PSUs often have a problem where they shut down during gaming but they work fine every other time. That largely is due to the heat generated when the video cards are actually working hard. That's why it only happens during gaming. The PSU fan is good enough...