RHR is usually defined as your heart rate while being in complete rest (lying down) but awake as far as I know. The best time to measure would be a minute or so after waking up I believe (but still lying in bed) or after lying down for ~10 minutes or so.
The way garmin calculates it might be a bit different, their algorithms have to take into account bad readings so I believe they use an average and/or ignore extremes.
But calories burnt are also dependent on your HR measured I think, so make sure that your HR is registered (semi) correctly.
I haven't really digged deep into all this though, I take all the info from the watch with a grain of salt and just check the steps and hr on a regular basis, and use it to run ;)