As long as miners switch back to the new longest chain after they
validate the block, mining on top of the
non-most-work-but-surely-valid may be less risky than mining on top of
a most-work-but-potentially-invalid block.
If they successfully SPV mine, they risk having mined on top of an
invalid block, which not only means lost coins for them but high risk
for regular SPV users.
It is important to note that while SPV mining requires you to produce
empty blocks, mining on the previous on top of the previous block
allows you to include transactions and earn fees.
In a future where block rewards aren't so overwhelmingly dominated by
subsidies, the numbers will run against SPV mining.