Developing websites are time-consuming. To improve productivity, I would code a prototype to show to our clients. I don't worry about making the prototype comform to the standard. Most of the time, our clients would approve the prototype and give an unreasonable deadline. I usually end up using the prototype in production (hey, the prototype works. No need to make my job harder.)
I could refactor the code to output valid HTML. But is it worth the effort to output valid HTML?