Both. The 180 degree rule just makes sure motion blur looks as intended and is a mostly artistic choice that can vary depending on the scene. E.g. for action sequences or particularly smooth motion in a dreamy scene, you can break this rule. Or, if there's moving water, you might want to choose a particular shutter in relation to the preset frame rate.
The overall frame rate gives you the distinction between a typical movie vs a TV-style documentary. The overall frame rate stays fixed across a movie and should normally not be changed.
My artistic choice is shooting 60FPS at 360 degrees (shutter: 1/60th of a second). It gives motion blur more comparable to 30FPS (which is closer to 24FPS), with the responsiveness and fluidity of 60FPS.