Something like 60% of voices come through the center, so to me very important. You could make your receiver shift this audio to the fronts, but I personally don't like that.
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Depends on your room and seating, if you have poor seating arangement with few good seats...a center is very important. Nothing worse than watching a movie and having the voice come at you from left or right of the screen.
In larger room with great seating flexability you may prefer no center speaker at all because voices will be center as they should be.
The better your main speakers, the less need you have for a center channel, even for off axis listeners. Speakers that image well can hold a strong center image even if off axis. A dedicated center is usually placed below or above the screen (with the exception of perf screens). The voices never sound like they're coming from the screen. A phantom center actually makes the voices sound more like they're coming from the screen.
I've tried both and prefer with the center channel. It seems more focus and involving. The other thing that bugs me about phantom channel is that on some DVD extras, it doesn't work without a center, all I hear is the info coming from the LR, I think they assume I have a center, or am I doing something wrong?
For music, where there is no screen to get in the way, the center front speaker is far and away the most important. This has been true from the earliest days of stereo sound, and did not have to wait for multichannel discs. For movies or TV I think that the best solution is two center speakers close to each side of the screen. This is better than diverting the center signal to the more widely spaced left and right front speakers.