There are a couple factors to consider.
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War Defence. Taking the +36 health option WILL result in your war defence being worth more points. period.
The GOAL of war defences is to get every single defence worth equal points. thus there is no “easier kill for points” option. -
Offence vs. DoT. Taking the health option will give a better survival rate against DoT heroes appearing on defence… +36 won’t do MUCH but it’ll do a wittle bit.
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Minions. If the hero creates minions, having the extra HP nodes will give the minions spawned more bulk (as minions inherit stats from the CASTER not the owner).
For me personally, if the hero appears on your war defence, take Defence over HP. Otherwise, the HP node IMO has more value.