Just sleeping in the bush is a bit risky, any one or anything walking by can stumble upon me, and I have no vantage point if I hear anyone coming. Building a shelter out of scraps will use up my energy and it will be a very probable place for someone to come scavenging for fire wood or what ever else they can find. I am a light sleeper, and i have my clothes and a belt to tie myself off with up in a tree, so I climb up, just enough to be difficult to see from the ground but not too high where a fall could cause major damage. Besides being a light sleeper, I should be able to hear anyone approaching and have a good vantage point to scout out the land around me.
Making sure I secure my pistol and the beef jerky I found, I climb into the tree, scout for some food and any information I can gather then tie myself off in a sitting upright position, and begin my rest choosing option 2.