As cheap as bluetooth earphones/headphones are now, I rarely plug into wired headphones. Even in the rare instances where I do plug in earphones, I never thought the connection on top was that big an issue. If the wire was draped over the front of the screen, I'd just twist the connection so that the cable would drape behind the screen (and I could keep the wire behind the screen with my hand).
I personally think earphone connection placement is just a petty way for people to compare the iPhone and the Note. I'd rather compare how the Note 4 is actually packaged to be a phablet where the iPhone 6+ is just an iPhone 6 with a gland issue.