My apologies, I didn't realize when you said place the view below that that was everything you wanted to do.
As Frederic indicated, the position of the label is easiest controlled by the Inventor Styles, as I assume you know this, then there is probably a reason you still want to set certain views programatically. Rather than tell you to change the style I'll do my best to help you move the view label.
Something to know, is that the 'position' of the view label is nothing a simple as a 'top' or 'bottom'. Those settings in the styles are simply instructions to help place the label correctly.
In order to change the position of a view that already exists using the API, you will have to modify the position (point2d) of the label in reference to the view it is attached. I would suggest getting the bottom edge of the view, offsetting your label down a set amount from it and centering it.
It might look something like the following. (this is just some back work, i didn't test any of this
)
Dim oView As DrawingView
xPos = oView.Left + (oView.Width/2)
yPos = oVIew.Top - oView.Height - 2 'Adjust the 2 as needed
oVIew.Label.Position.x = xPos
oView.Label.Position.y = yPos
If you have trouble applying this solution let us know, we'll probably need a sample to work with if it's more complex than have view need label...
Best of Luck
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