But those that have fun writing code usually do, or have done so at some point. It's some kind of filter, that's true, and there isn't any filter that's always fair.
I would think the both to be almost same as long as you can tie your name to the App/Software you deployed in Google Market. In one scenario I get to see actual code and in the other a final product that has been deployed to the market. Both, having being done as a side project should be considered equal