Sielle: Simply put, because it's not necessary for them to not be. The seeds themselves don't require the protection of the ovary, nor are they required for proliferation of the plant.
It's a simple trait that started out as a random mutation that didn't hamper the plants ability to survive so it spread. Remember that not all mutations have to be beneficial, they just have to NOT be detrimental to the survival of an organism.
This is a point which a bears repeating. Sometimes things like that happen because there's a reason for it, and sometimes they happen because they just happened and nothing has come along to prevent it.
Take the black squirrel, there's no particular reason for it to exist, but the melanistic subgroup isn't sufficiently damaging to it that you do see them pop up from time to time. And apparently in a few areas they're the dominant sub group rather than the more typical eastern grey.