Did they include by URL or by file path?
If they included by file path, this would have caused PHP to repeatedly include the same file until it got bored (unless any functions or constants were defined in the include, in which case it would fail with a fatal immediately). This would not have caused any load issue.
If they included by URL, then it may have appeared as a "fork bomb". This indicates that your Apache MaxClients is set too high.
Don't set Apache MaxClients higher than your machine has resource for and/or you need. In most cases this means no more than about 50.
Setting MaxClients to 1000 etc (especially on prefork MPM which is FAR less memory efficient than worker), is stupid.
Once you upgrade to PHP 5.2, you can disable inclusion via URL (indeed, it is disabled by default). Until then you have to tell people not to use it.
Perhaps you can grep for
include("http://
or similar and find those pages and mail the irresponsible authors.
Another possibility is to set up IP address restrictions to prevent your web server connecting to itself.
Mark