One reason why Unix quotas are generally not maintained and imposed by path is that it's a lot easier to update quotas as things are created, deleted, modified, and so on if the only thing that matters for who gets charged is some attribute of the inode, which you always have available. This was especially the case in the 1980s (when UCB added disk quotas), because that was before kernels tracked name to inode associations in RAM the way they generally do today. (But even today things like hardlinks raise questions.)

(I'm the author of the linked-to article.)