Even if there is a residual charge, depending on how long ago the testing was done it could be so nominal that the phone won't function or function just enough to last a few minutes. Hardly a reliable phone.
It only has to last for a few milliseconds: "Aging of lithium-ion is an issue that is often ignored. A lithium-ion battery in use typically lasts between 2-3 years. The capacity loss manifests itself in increased internal resistance caused by oxidation. Eventually, the cell resistance reaches a point where the pack can no longer deliver the stored energy although the battery may still have ample charge. For this reason, an aged battery can be kept longer in applications that draw low current as opposed to a function that demands heavy loads. Increasing internal resistance with cycle life and age is typical for cobalt-based lithium-ion, a system that is used for cell phones, cameras and laptops because of high energy density. The lower energy dense manganese-based lithium-ion, also known as spinel, maintains the internal resistance through its life but loses capacity due to chemical decompositions. Spinel is primarily used for power tools."
http://www.batteryuniversity.com/parttwo-34.htm