I guess you're talking about these recommendations: Recommended Project Directory Structure.
The interesting parts are:
data/: This directory provides a place to store application data that
is volatile and possibly temporary. The disturbance of data in this
directory might cause the application to fail. Also, the information
in this directory may or may not be committed to a subversion
repository. Examples of things in this directory are session files,
cache files, sqlite databases, logs and indexes.
temp/: The temp/ folder is set aside for transient application data. This information would not typically be committed to the
applications svn repository. If data under the temp/ directory were
deleted, the application should be able to continue running with a
possible decrease in performance until data is once again restored or
recached.
Now, you can understand that Zend doesn't recommend to store your Zend_Cache data into data/cache/ only, but it could also be stored under the temp/ directory. The real question is: should I commit these data cache files and are they necessary for the application to run correctly? Once you answered these questions, you know where you should put your cache files. In my opinion, in most cases cached data should be stored under the temp/ directory.
Finally, remember that this is only a recommendation, you are always free to do the way you want.