I don't think it really matters to be honest. If the candidate has the skills they will be found. The big variable here does the recruiter have the knowledge of their ATS to search it effectively. An ATS will not care or recognize one format is better than another. How the ATS presents the resume to the recruiter could vary, which in turn could push an impatient recruiter to now view the resume.
You can never wrong with straight text
What suggestions would you give a candidate in order to have their resume moved to "the top of the pile" when submitting a resume via an ATS?