It depends on the efficiency of the regulator. The engineering side is picking a regulator giving good efficiency given the battery voltage isn't really constant, it decreases over time. Regulators don't have constant efficiency. They will vary based on input voltage and output voltage/current, and different regulators have different sweet spots.
I use buck regulator VV, stacked 3.7V batteries, which means fresh batteries are really pushing about 8.4V, decreasing over time to about 6.5V. With my gear, I'm better running 3 ohms at 5.5V (10.1 watts) rather than 1.5 ohms at 3.9V (also 10.1 watts) -- it's a more efficient operating zone for the particular regulator and batteries.
Personal preference comes into play. I happen to really like some cartos and atties available at 2.5 ohms, so trade a little run time by using them somewhere in the 4.5 - 5V zone most of the time.