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It's not automatic. I think the anchor point for the label is its upper left corner, and it always places it "one line" above the node. Then the text grows down or right from the anchor point. There are some ideas on the Idea Exchange about making labels smarter (mostly for FP terminals).
With 2012 and later you can change the default label justification for vi's on a BD. VI's labels fall under "Other" There is even a checkbox to automatically show subvi labels. set the option to right-top or bottom anything and the growth won't cause grief. (Well, bottom-xxx may interfer with polymorphic selectors) Also uncheck "Labels locked by default" to make it easier to move labels on new vi's. There is a Right-click setting to lock/unlock labels on individual objects