When it comes down to it, history judges NFL quarterbacks on ONE major category.
Is Dan Fouts often mentioned among the league's most legendary quarterbacks?
What is the one thing that's said about Dan Marino every time his name is brought up?
Do people talk a lot about Joe Montana's passer rating or pro bowl selections?
Do you happen to know the statistical prowess or all-pro award count for Bart Starr, Otto Graham, or Roger Staubach?
Everything else is essentially a footnote. It's all about the ring count. Unless you are trolling around comments sections looking for negativity, you'll find a near unanimous consensus that Brady is the greatest QB ever, and this is less than a year removed from his BS suspension.
I agree that rings are usually given a very importance when judging QBs. But it shouldn't be just that : no way Trent Dilfer and Brad Johnson are better quarterbacks than Marino, Tarkenton or Fouts.
But for some reason, when looking at Elway's career for example, he now ranks higher because of the 2 Super Bowl wins at the end of his career than we would have if he had retired after the 1996 season. But the Elway that won those 2 Super Bowls was not as good as the one who lost 3 in the 80s. And nobody will convince me to put Manning higher on my list because he won a 2nd Super Bowl.
Volume stats will help to get mentioned among the greatest, but then again, it's not the definitive argument in evaluating a QB. Nobody has ever said Tarkenton was the greatest of all time, yet he was the career leader in TDs and passing yard for a long time before Marino passed him. And nobody is putting Testaverde into a top-20, even though he is just that when looking at his career stats. Changes in rules over the years has changed the game, and the stats, so this is not a very good compare point when looking over a 100 years of professional football.
I would put Brady as the greatest, because he's won a lot, he's always been above the league average in efficiency metrics and the offense he quarterbacks is constantly at the top of the league (points-wise) every year. But I've never seen Starr play nor Graham, Luckman and Baugh, so for me to say Brady's the best ever might be a bit presumptuous.
We also tend to place higher ratings to players that are still active. Brett Favre was always in discussion among the best ever when he was playing, but now, 7 years after retirement, I don't see him being in the top-5 on most lists. I have this impression that with each passing year, Manning's ranking will get lower and lower as well.