What is the test for establishing probable cause under the substantial evidence rule?

testing is "strictly limited by statute" and conditioned "upon a finding of probable cause" and "[w]ithout evidentiary support the order is invalid." (People v. Butler, supra, 31 Cal.4th at p. 1123.) "Under the substantial evidence rule, a reviewing court will defer to a trial court's factual findings to the extent they are supported in the record, but must exercise its independent judgment in applying the particular legal standard to the facts as found. [Citations.]" (Id. at p. 1127.) "[I]f the trial court orders testing without articulating its reasons on the record, the appellate court will presume an implied finding of probable cause. [Citation.]" (Ibid.) "[T]he appellate court can sustain the order only if it finds evidentiary support, which it can do simply from examining the record. Moreover, even if the prosecution could have established probable cause, in the absence of sufficient evidence in the record, the order is fatally compromised. [Citation.]" (Ibid.)