We could treat ANT as a transformer, from microstrip line to air.
The max efficiency of ANT is 1, so ANT's gain must be lower than 0 => negative gain;
High gain means ANT's power concentrate in some direction, but the efficiency is still small than 1 in total...
For cell phone, ANT is omidirectional, it's good if you could get more than 50% efficiency (more than -3 dB gain).