Hi,
Perhaps you have fixed your problem, but if not here's a few ideas.
There are many possible causes for poor phase error in a GSM handset,
here are just some I have come across :
-TX VCO pulling due to RF power from PA : poor layout of RF
-faulty PA device
-PA power control fault/noise
-faulty TX VCO : spurious on output
-misaligned/faulty IQ modulator
-IQ data corrupted/incorrect/noisy
-RF feedback to device regulators/supplies
-faulty PLL components (loop filter caps correct value ?)
-TX PA outputting too much power ?
-VCXO faulty : too noisy, adds to PLL noise
-and others.. such as smd faults on asic balls or shields
without more details of the GSM handset in question it's difficult to
be anymore specific...
Martin