What is the current state of the law on the burden of proving a suspect without a warrant?

People v. Rice (1967) 253 Cal.App.2d 789, 61 Cal.Rptr. 394 followed Harvey while summing up the problems of proof in cases such as that at bench. "When suspects are arrested without warrant by officers who have not, themselves, gathered all of the information which gives rise to probable cause, peculiar problems of proof arise. On the one hand, it is obvious that the law cannot demand that investigations be conducted by single officers who then must also make the arrest. Criminal investigation is not that simple. [p] On the other hand, the mere fact that the arresting officer believes, in all good faith, that somebody else has gathered sufficient information to make the arrest legal, cannot relieve the prosecution of the burden of proving the legality of the arrest, if it is challenged. [Citations.]" (Id. at p. 792, 61 Cal.Rptr. 394, emphasis added.)