The general rule of thumb that I have seen suggested over and over, is if your text file will be more than 100 or so lines of data, a data base should be considered.
You need to consider how often it will be accessed, written to, read from ect.
If the text file is serving your purpose, I wouldn't worry about it, unless you expect it to become quite busy with requests.
I have found you need to screen the data more thouroughly with a text file, than with a data base. With a data base, you just need to make sure that numerical data is numerical, and text is being run through addslashes(), or magic_quotes_gpc is active. With a text file, you need to also be concerned with newline, and carriage returns.