Karen Ristevski's daughter has provided a Melbourne court hearing with a "glowing reference" for her father, who killed her mum and lied about it for two years.
Sarah Ristevski has provided a "glowing reference" for her dad Borce, who killed her mother Karen and hid the body in a forest to rot.
The Supreme Court of Victoria was told on Wednesday that Sarah would not provide a victim impact statement like nine of her relatives, but would instead stand by 55-year-old Borce Ristevski, who earlier this month pleaded guilty to manslaughter.
One of those family members, Karen Ristevski's aunt Patricia Gray, wept as she recalled making and distributing flyers when the 47-year-old went missing in June 2016, while the killer lied to his family and the police.
"It was very uncomfortable to watch as he manipulated his family," Ms Gray told the court.
"He and his vicious lies ... were agonising."
Ms Gray said Ristevski "bullied" his daughter into defending him, manipulating and lying for more than two years.
The court was also told on Wednesday that Ristevski first offered to plead to manslaughter following his murder committal hearing in September last year.
"The offer was devoid as to any explanation as to what occurred," chief crown prosecutor Brendan Kissane QC said. "For that reason it was rejected."
He had earlier said Ms Ristevski's cause of death was still unknown.
"Only one person knows why or how Karen Ristevski was killed, and that is the prisoner."
The murder charge was dropped on March 13 after a court ruling that prosecutors couldn't rely on Ristevski's conduct after his wife went missing to prove murderous intent.
Ristevski admitted to killing his wife following arguments about their precarious financial situation.
She was not found for almost eight months and an autopsy could not determine the cause of her death.
A statement read to the court on Wednesday by Stephen Williams, Ms Ristevski's younger brother, said when he caught up with Ristevski, he "only spoke about himself".
"The lies and deceit started immediately," he said. "Unlike others, I could see through them."
"At what stage can we say enough is enough when it comes to domestic violence?"
Aunt Marguerite Knight said she had "total belief" Ms Ristevski would never leave her family willingly.
"Never once did you say you missed Karen. It was always about you," she said in comments aimed at Ristevski.
"What monster does this unforgivable act then walks away? How did you get so cruel?"
The court was also told the macabre details of how Ms Ristevski's remains were found by two horticulturalists.
"They were drilling into the base of a pine tree when they smelled an odour," Mr Kissane said.
"They observed a human skull and a foot. She was almost completely concealed beneath a jungle of logs and branches."
Mr Kissane said there was no evidence of Ristevski showing remorse. He is due to be sentenced on April 18 and the maximum jail sentence for manslaughter is 20 years.
If you or someone you know needs help with sexual assault, domestic or family violence and abuse, call 1800RESPECT or visit 1800RESPECT.org.au