Makes very little difference, once your under the car and see the sump you'll understand.
My tips would be ...
1. Leave it to drain longer by changing cabin filter / air filter while the plugs out and its dripping.
2. Top up until it is just on the dipstick, start and run while still on the ramps so you can check for leaks (peace of mind, never seen a leak)
3. once its on level ground and has been running let it stand for 5 mins then re check oil level and top up as required. It's much easier to add more than remove some!!
4. Make a note on your parts reciept of date work done - nice to pass on with car paperwork when the time comes.
I got myself a pair of caravan leveling ramps from Ebay which I screwed to some 18mm mdf and its high enough to enable me to do an oil change without any jacking up. While under the car I always spray lube and suspension and drive points with spray grease.