I never pay attention to that or mine might not get water most of the time I think the idea was started with greenhouse growers wanting the plants dried off by night. But with fans going, I don't see the problem, myself. I water when I get to it.
If we followed that rule we wouldn't water our orchids between November and June! More important (as noted by Ross) - don't water as temperatures are dropping (towards evening) where the crowns and knotches of the plants may keep standing water in them for periods of time - which promotes disease organisms.
I believe that guidance originated from the concern about having water sitting on the leaves, in the leaf axils, and the like - which is more likely in dull, gray weather and night than it is on a sunny day. Plus, on a sunny day, the plant's processes are really cranking, so it can absorb and incorporate more water and nutrients.
Being more of an indoor grower, I don't pay attention to the weather outside. If their under lights being fanned and need watering, that's what they get