The family of a Melbourne woman murdered by her ex-husband four years ago may still have a long wait until her killer is sentenced.
Fernando Paulino, 56, was found guilty in June of murdering his ex-wife Teresa Mancuso, 49, who was stabbed 16 times at her parents' Reservoir home in 2013.
Counsel for Paulino and the prosecution appeared before the Victorian Supreme Court on Friday for a mention as Justice Kevin Bell prepares to sentence the man.
Justice Bell indicated a High Court judgment on Wednesday, which overturned a sentence for incest, could affect Paulino's sentence.
The unanimous High Court ruling found that current sentencing practices are one factor, and not the controlling factor, in determining a "just" sentence.
Justice Bell on Friday said the community's view "has hardened" towards violent crimes against women committed by men, which should be reflected in the sentences that perpetrators receive.
The prosecution and defence have been given another opportunity to make submissions about how long Paulino should spend in jail.
All parties are due to return to court on November 17 for a further pre-sentence hearing.
At this stage it's unclear when Paulino will be sentenced.
At a hearing in August, Paulino interrupted his son Luke's victim impact statement to protest his innocence.
"It's tragic and horrific what happened to mum but I didn't do it," Paulino cried out on August 16 as security intervened.
Paulino later apologised for his outburst.
A jury in June found him guilty following a month-long trial of murdering his former wife of 23 years.