Well, it's up to you. You can do the same thing in several ways.
Using a Point means you must create a Point for every label. This can be OK, and can even be beneficial, or it can be unwanted overhead. It depends on your circumstances.
You can create very similar Spot Elevation, or use Generic Note labels with Surface reference text. If you use Spot Elevation labels, note that there's no way to change the surface associated with a spot elevation after you create it. This may or may not matter to you, depending on what you are doing. But if you think you may want to change a bunch of labels to point to a different surface after you create them, use the Generic Note Labels with Surface reference text instead of Spot Elevation labels.