While this is so very true in the theoretical sense of the term, I gave this a very short thought, and there might be edge conditions that could indeed lead to "better power with tree-shaped panels" (1), now that I think about it. There is a term that you are (rightfully) neglecting: the size of the system, and incurred energy loss due to Joule Effect.
If the distance between panels arranged in a linear way is large, then it might be more efficient to place additional panels closer to the output circuit, maybe above it, in such a way that it doesn't overlap and yep, maybe even with a different orientation, just to optimize the distance between producer and consumer, and thus reduce resistance and energy losses. But that would probably only be valid for specific sets of distances, positions, hour of the day (seasons, voltage, quality of the conductor material...), but that's only because the studied system shifts to be more of that of an Energy Transmission System than that of an Energy Production System
(1) or sphere-shaped or pyramid-shaped or pokemon-shaped for that matter...