The case has 6 sides.
Measuring the bottom side metal case, the R
j-case is given. (not the top)
When there is no heatsink other than the minimal pads on FR4, the R
j-pcb thermal resistance is much higher.
This reduces the resistance in half.
So if testing the thermal resistance of the PCB layout, one would use the thermocouple on the PCB next to the case rather than the top case which may have more thermal gradient than the PCB close as possible, (check and possibly on the other side of the board)
The point of the OPs confusion seems to be where on the case this applies as there are many variations of case design including Al, Cu and Steel framework inside the plastic and some have heatsink interfaces to the PCB interface. There are obviously 6 sides of the case and only 5 accessible when mounted, so the T.pcb is a convenient reference point used by some but not all OEM's.
When in doubt, use the PN junction voltage drift in an oven to calibrate your chip in oven, chip on board powered up at room temp. The oven with a known low DC current in low power <<1 mW will be an accurate thermometer for the junction.
But this should always be true.
θ
JA = θ
JC + θ
CA.