To the original poster,
many people on this thread aren't familiar with a marraige by proxy - which is what your friend had. Are they from Pakistan perhaps? [where such is legal, and recognized]. Income won't be required for a spousal sponsorship - but just insure that such a marriage is legal in the country where it was performed.
For a telephone marriage to be recognized in Canada, it must be recognized in the country where it is performed in. So he would have to prove to CIC that a telephone marriage is legal in that country. Here is what CIC has to say:
Telephone marriage A marriage in which one of the participants is not physically present and is not represented by a proxy but participates directly by telephone is a legal marriage if it is legally recognized according to the law of the place where it
occurred. This is a legal marriage for immigration purposes provided it meets the Canadian federal requirements, with respect to consanguinity and polygamy/bigamy.
Here is a good link that also discusses Marraige by Proxy - or telephone Marriage
http://www.canadavisa.com/canada-immigration-discussion-board/-t6033.0.html