Cutler was far from his best when Phil beat him. Doubt Phil would come even close to 2001 or 2009 Cutler.
And yes, I'm a Cutler fan, so my post may clearly come off as biased 
Coleman was far from his best when Cutler beat him.
Cutler was also far from his best when Jackson beat him.
It happens.
Arguably, the only Mr. Olympia who lost his title at (or near) his best was Jackson.