Leading 3-1 at St James' Park, West Ham were beaten 4-3 on the day.
Advertisement
Advertisement
Phillips was a second-half substitute and gave away a penalty to spark Newcastle's fight-back.
The Manchester Evening News says after the game, Phillips was barracked by waiting fans in the stadium carpark.
Once on the team bus, he turned and aimed his middle finger at the West Ham fans, who then responded, "get out".