Only reason is because Joe played on 4 Championship winning teams. The public only judges on the super bowl rings a QB has. That NFL vote will come down to Joe VS Tom. 4 rings vs 3 rings, that's just the way the public judges. Everyone knows that as far as the position of QB goes, Joe is no where close to Marino. Sure Joe has the rings, but has any of these so called people who vote for him as the GOAT, even do any homework on those 49er teams?
Facts are
Walsh made Montana with the west coast offense
Montana was bad until halfway through his 2nd season, which was when he started to get a handle on Walsh's system
Montana was fragile, always getting hurt.
Was pulled from some games for inability to get it done in late 80's, and was replaced by Young. (I have never seen Brady, Manning, Marino, Elway get pulled from a game for bad play)
Had QB controversy with Young, even Walsh admitted he was not 100 % behind Montana once Young proved he could get it done. (I don't know of any GOAT who was in jeopardy of being benched for another player)
Montana had the benefit of playing with a top 5 ranked defense EVERY YEAR they went to the super bowl
Montana had the benefit of having over 100 + yard average running game behind him, every year they went to the super bowl
Had a dynasty behind him, COMPLETE all around GREAT TEAMS!
Anyone who has watched the two play, knows Marino was hands down the better QB. Yes Montana was good, Montana was smart, Montana was clutch in some big games. People should realize that a lot of that credit also needs to go to the coaching staff for putting together some great game plans in those big games, a lot of the credit needs to go to the defense for shutting down opponents in those big games. Those defenses always shut down their opponents. How many shoot outs did you see those 80's 49er teams win? Not many, because there were none, due to that dominating defense they had. How many playoff games those 80's teams had, where their D held the opponents to under 10 points? The Bears, The Rams, are 2 I think off right off the bat. There were others. Give that Defense the credit they deserve, not all to Montana.
Marino never had the opportunity that Montana had to be clutch in 4 super bowl's, never had the dominating defense and 100 yard running games to make his life that much easier. It was always Marino pulling a 4th quarter comeback, or leading them to a score only to watch the defense give up a last minute FG or TD to cost them the game. How many times have we all watched Marino standing on the sidelines helpless as the opponent ran down the clock with pounding the ball on our D or converting 3rd downs?
People don't realize all of that, all they look at is "Montana 4 rings, Marino 0" and that's how they judge. Anyone with NFL knowledge and that actually takes a little bit of time to looks at all the FACTS, knows Marino hands down was the better QB.