Always drive the bottom plate if the cap is at lower
levels and C to substrate is the largest parasitic term.
But if you had (say) a 6LM process, routing power and
ground on M6 and the MIM cap is between M4 and M5,
you'd probably drive the M5 top plate (liable to be loaded
by bussing overflight) and take signal off M4.
As a rule you want to drive the more heavily loaded
plate, so that capacitive division and spurious coupling
is minimized on the "output" plate.