My understanding is that the cell towers act as differential GPS? No?
Wikipedia tells me that many phones use "Assisted GPS", where the phone uses information delivered through the cell network to help it figure its position and speed up the initial position fix. It also says "Some A-GPS solutions do not have the option of falling back to standalone or autonomous GPS." That might explain why some phones don't have functioning GPS when there is no cell signal.
Differential GPS is something else completely. No idea if phones are using it.