I prefer the bypass valve at the base, like on the Mopar filters. Having said that, the unfiltered oil bypassing at the cap end probably makes no difference. In a bypass situation, it's unfiltered oil anyway. As to the filter being vertical, I wouldn't worry about that either.
How often does a bypass situation exist, that's the question. Probably more often than one thinks.
2007 GC SXT - Magnesium - S&G - 3.8L - 173,000 kms
2002 GC Sport - Stone White - 3.3L - 358,500 kms
2003 Jeep TJ Sport - 4.0L - 279,000 kms