Borce Ristevski, 55, has returned to court after his explosive admission earlier this month that he killed his wife, pleading guilty to manslaughter.

Karen Ristevski's body was found in the Mount Macedon Ranges.

During a pre-sentence plea hearing at the Supreme Court of Victoria on Wednesday, statements were read by a number of Ms Ristevski's family members.

Patricia Gray, Ms Ristevski's aunt, wept as she spoke about how she'd made and distributed 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.

"I prayed for some kind of divine intervention.

"This crime is too great for forgiveness."

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Ms Gray said Ristevski "bullied" his daughter Sarah into defending him, manipulating and lying for more than two years.

Ristevski admitted killing his wife following arguments about their precarious financial situation.

After his wife's death, Ristevski shoved her body in the back of her Mercedes Benz, drove towards Macedon Regional Park and turned off both their phones on the way.

He dumped his wife's body between two logs in a forest before covering her in branches.

She was not found for almost eight months. A pair of horticulturalists stumbled across her skeletal remains.

An autopsy could not determine the cause of her death.

A murder charge was dropped on March 13 when a Supreme Court judge ruled prosecutors couldn't rely on Ristevski's conduct after she went missing, to prove murderous intent.

A statement read to the court by Stephen Williams, Ms Ristevski's younger brother, said he only found out on Facebook that his sister had gone missing.

Mr Williams said when he caught up with Ristevski, he "only spoke about himself".

"The lies and deceit started immediately.

"Unlike others, I could see through them.

"At what stage can we say enough is enough when it comes to domestic violence?"

The plea hearing continues.

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Australian Associated Press

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