I think on a lot of his driver shots, Phil (also Tiger, and many others) do hit down on the ball (negative Angle of Attack).
This leads me to one of my biggest beliefs (so far...), that there is a trade off between efficient impact conditions and efficient launch conditions (see earlier thread). I think the best players will still hit down on the ball (or at least not hit up on it as much as is "most optimal") because their swing is better when they do.
I also don't like confusing the "optimal" term with maximizing distance. If I maximize my distance into the bush, how optimal is that? "Optimal" to me means something more than just the most distance.
Bubba Watson has shown a great ability to hit more up on it when he wants to bomb it, but also hit down on it when the shot calls for a fairway finder.
My hypothesis (I eagerly await the trackman data on this) is that the most consistent, accurate drivers of the ball will hit down on the ball (or at least not hit up on it as much), and the best overall drivers (PGA TOUR's stat combining distance and accuracy rankings) will be the guys able to vary their attack angle.