Can an officer make a warrantless arrest when the officer has probable cause to believe the person to be arrested has committed a public offense?

As relevant here, an officer can make a warrantless arrest when the officer has probable cause to believe the person to be arrested has committed a public offense in the officer's presence. ( 836, subd. (a)(1).) " 'In dealing with probable cause, . . . as the very name implies, we deal with probabilities. These are not technical; they are the factual and practical considerations of everyday life on which reasonable and prudent men, not legal technicians, act.' [Citaion.] [] [P]robable cause is a fluid conceptturning on the assessment of probabilities in particular factual contexts . . . ." (Illinois v. Gates (1983) 462 U.S. 213, 231, 232; see also Maryland v. Pringle (2003) 540 U.S. 366, 371 ["The probable-cause standard is incapable of precise definition or quantification into percentages because it deals with probabilities and depends on the totality of the circumstances."].) However, the high court has stated that " '[t]he substance of all the definitions of probable cause is a reasonable ground for belief of guilt,' [citation], and that the belief of guilt must be particularized with respect to the person to be searched or seized, [citation]." (Maryland v. Pringle, supra, at p. 371.) In other words, "[p]robable cause exists when the facts known to the arresting officer would persuade someone of 'reasonable caution' that the person to be arrested has committed a crime. [Citation.]" (People v. Celis (2004) 33 Cal.4th 667, 673.)