Panicked or distressed divers will often reject equipment and the mask is one of the things to go when at the surface...got4boyz once bubbled...
If I was in distress I can guarantee I'd have a better way of showing it that putting my mask on my forehead!
Because so many have been taught to recognize this as a distress sign you should not do it unless you are in distress.
But there is another reason.. a mask on the forhead has a tenuous perch and can be easily knocked off. A mask under the chin is ok unless you are using a necklaced back up regulator... in which case you want the mask on the head turned around backward.... this backward facing position is very secure and even if you were to have the mask drop off backwards it would be caught by your regulator and hoses instead of dropping forward into the drink.