Well, of course it is a non-code way of doing it.
However buys the home from you will have to live with the problems that you've created. In a court of law, I would assume he could collect damages.
All fittings below the flood level of a fixture are designed to speed the flow.
When a santee is on it's back, unstead of shooting the waste and water downward and out, it drops straight down in a pile.
When the santee is vertical, it's dropping down the pipe anyway. Thats why they are allowed on the vertical.
When the santee is on it's side, it's the same as on it's back. The waste piles up at that spot.
If you have to run a snake down the line, it's much easier if the sweeps are on 45's.
If you run the santees wrong, your odds of needing to snake go up, and the difficulty too.
The cost factor between the two is almost nothing.
One plumbing call will more than pay for the initial savings by not using the right fittings.