well it should follow the axial tilt...because in space there s no real up and down or angle...its all base on objects vs an other one...
So if Primary object avec an axial tilt of 35 degree...then the 0 degree should be at is equator for all bodies orbiting it...
So let say you want to have a body at 15 degree vs is main planet that have an axial tilt of 30 degree...instead of putting 45 degree...you only put 15 degrees and you don t need to play with the node to orient the orbit a the equator line.
Then we could devellop way much more realistic systems and orbit.
Here is a system i did made...i did try to orient all the moons around the equator with some little angle...let me know what you think.
Did this system via an accretion disk method i ve been updating since 4 yrs now...now it work pretty well to make realistic systems
...did use it too for the planets-moons systems