If I spend my hard earned money and see a show, and this happens, I'd talk to the house manager and either try for a refund or to get my ticket past dated. Reason being is that I didn't pay to see an actor yell at the audience. I paid to see the show, and clearly yelling at one audience member isn't in the script or part of the show.
The thing is that there are many people who go to the theatre, hate the usage of cell phones, yet use it themselves. For example, I remember being at a performance of Time Stands Still. It was there that a guy sitting next to me got a little annoyed (rightfully so and not over the top in any way) about a someone's phone going off. However, this is the same person, that took out his phone to text during the middle of the second act.
And, Ghostlight, the whole "yelling at someone if what they are doing is bothering you/getting in your way" is just plain silly. It's about maturity and being the grown up in the situation. Sure, the person filming is in the wrong, no doubt about it. But, acting like a child when you're a grown man doing a show is sad and pathetic .
"If you try to shag my husband while I am still alive, I will shove the art of motorcycle maintenance up your rancid little Cu**. That's a good dear"
Tom Stoppard's Rock N Roll