While I was assessing a new client I noticed that Google was showing nice headings for then in the search results, even if they had a blank title tag!
It looks like Google is pulling the headings from the copy if the title is of no use.
My example. If you search on "Consult with clients to explain investment strategy" (with quotes) you will get my new prospective as the only result. Check their page to see it has a blank title tag and the search result heading comes from initial text in the copy.