In my understanding, the reason these other LEDs aren't low voltage has nothing to do with use in flashlights, or even off batteries, because they're not designed for that. They're meant for light-bulb replacements and such, where 12V and up are at least as easy to get from 120V or 240V as 4V and down. The manufacturers of even the nice flashlight emitters (SSC and Cree) seem to consider the flashlight market of only minor interest.
So when nobody's thinking about batteries at all, the first consideration takes precedent, and they're wired in the logical series or (where voltage considerations dictate) series/parallel.