What is the burden of establishing that a defendant waived his right to counsel at trial?

Furthermore, on appeal the defendant has the burden of establishing that he did not competently and intelligently waive this right. (People v. Kranhouse (1968), 265 Cal.App.2d 440, 447, 71 Cal.Rptr. 223.) While it would have been desirable to have an explicit determination of an intelligent waiver appear upon the record, it is not an absolute requirement; such waiver may be inferred from all the circumstances. (People v. Santos, supra, 245 Cal.App.2d at p. 340, 53 Cal.Rptr. 859.)

The determination of whether defendant intelligently waived his right to counsel depends upon the particular facts and circumstances surrounding the case, including the background, experience and conduct of the accused. (People v. Kranhouse, supra, 265 Cal.App.2d at p. 447, 71 Cal.Rptr. 223.)