A headphone could be 8 ohms or 600 ohms. So the voltage isn't rated, the power into a certain resistance is instead. Usually the output has a series 180 ohm resistor to limit the current. Then if the source has a 10V output, an 8 ohm headphone gets 23mW and a 600 ohm headphone gets 99mw.
If the current-limiting resistor isn't there then the 8 ohm headphone will get 12.5W and blow up (and your ears too). The 600 ohm headphone will get "only" 167mW which is pretty loud.