Shouldn't matter, afaik - so long as $Config{make} matches the make utility you're using, it should be fine.
However, I too would prefer to use dmake with MinGW and nmake with MSVC++ .... just in case :-)
I believe (untested) that you do need to use dmake if you want to build perl itself with MinGW, whereas you can build perl using either dmake or nmake with MSVC++ - and thats' something I *have* tested recently.