I've always found it doesn't matter. You should use whatever will make you the most productive, responsive to changes, and whatever is easiest to debug and maintain.
Most applications never need enough load for the difference between ORM and SPs to noticeable. And there are optimizations to make ORM faster.
Finally, a well-written app will have its data access seperated from everything else so that in the future switching from ORM to whatever would be possible.
