I guess so. My point is still that you're obfuscating if you're trying to do something like that, since the return value will be used by the caller regardless whether the programmer there chooses void as return type or not. The choice is simply not up the one writing the called function, but the one writing the function call (that would be different if there was a way to query the number of values the function actually returned).
In other words, since the function has to return zero to avoid some special handling of the return value, it's more clear - and hence more user friendly - to explicitly return zero and declare the function accordingly.
It's misuse to exploit void as a trick only to shorten the return zero bit slightly. It's unfortunate that the the current implementation allows it; it should have been an error at runtime too to use the return value from a void function.