I’m a strong believer in tabs at the top. This is one of the reasons recent gnome-panel defaults (at least in Gentoo, but hopefully we match upstream), where there’s a panel both at the top and bottom of the screen, annoy me. Be consistent, folks! Some people disagree with me, though. But I would argue that the location of your eyes while you’re typing in a terminal has no relation to the location of your mouse.
In my setup, I never have to move my mouse below the top 2/3 of the screen. If the menu is at the top, each windowbar should also be at the top. So should each program menu, and and tabs within that program. Making me move the mouse all the way down to the bottom of the screen to switch around terminal tabs is just as likely to make me switch terminals.