They keep finding ways to gut the controller’s battery life.
If you are buying PlayStation earbuds you might as well buy 2 more dual sense Controllers so you always have one fully charged ./s (though I wouldn’t be surprised if some middle level exec at Sony is thinking exactly this)
And, in this case, with a top mount, they would lose the functionality of the touchpad which has been in place since the PS4.
It would break functionality with PS4/5 games using the touchpad.
That’s in the back of the controller. If you open a dual sense you’ll see that the “only” thing that would be in the way of the charger is the battery.
Referring to some of the mock ups like this one:
https://gamerant.com/sony-new-ps5-controller-with-slots-for-charging-pulse-explore-inzone-earbuds/
It replaces the touchpad with the earbud charger.
The DualSense successor would feature a charging case-like compartment in the back where you can place your earbuds and charge them.
This article explicitly states where Sony wants to put the charger. Illustrations done to drive article views are not a good replacement to actually reading the text.
FTA:
“The charging slot could appear on the front, back, sides, top, or bottom of the device.”
The article says the ear it charger is under the touchpad.