It doesn't matter where it is placed as long as you can control that transistor. An NPN is usually used as a low-side switch because any base voltage more than ~0.6V above the lower rail will turn that switch fully on. A PNP is used on the high side because any base voltage ~0.6V below the upper rail will turn it full on. In either case, you could use a different arrangement but then you have to ensure the right voltages on the bases of the switching transistors, relative to their emitters.
An NPN can sit on top a 5V load instead of below it, but that means its base needs to be at >5.6V to turn it on. That is a useful trick used in an emitter-follower configuration, but if you just want to switch the load, it's easier to place the NPN below the load.
An NPN can sit on top a 5V load instead of below it, but that means its base needs to be at >5.6V to turn it on. That is a useful trick used in an emitter-follower configuration, but if you just want to switch the load, it's easier to place the NPN below the load.