Well, given that the possible range to a cell tower is about 35 km / 20 mi (max, an absolute limitation of how the GSM/timing is done), it's very plausible that even if cell broadcast antennas are generally pointed down + flat with the horizon, you're gonna get some signal from some antenna in the distance.
That said, you do get the occasional misaligned antenna or weird bounce off terrain that gets you signal midflight for a minute.