What is the test for a waiver of a defendant's right to counsel?

In a recent decision an appellate court held there had been no valid waiver of the right to counsel despite the fact that the defendant had agreed to his counsel's absence during major portions of the proceedings. (People v. McGraw (1981) 119 Cal.App.3d 582, 597-598, 174 Cal.Rptr. 711.) Similarly the defendant's failure in the case at bar to protest his attorney's handling of the defense does not remotely approach the constitutional requisites for a valid waiver.