Michael James Chalmers, 36, faced Melbourne Magistrates Court on Monday, charged over the death of Asian migrant sex worker Yuko.
The 62-year-old woman was found dead at the Footscray brothel she ran in Melbourne's west in late November 2024.
CCTV footage allegedly showed Chalmers speaking with Yuko for about two minutes before he grabbed her in a headlock and pinned her down on the bed, prosecutor Jordan Johnston said.
"The interaction commences with violence," Mr Johnston told the court on Monday morning.
Chalmers was captured on the footage leaving the brothel room about 30 minutes later while Yuko was either unconscious or already dead, the prosecutor said.
Two pathologists previously told the court Yuko likely died from strangulation or smothering.
The prosecutor said the injuries Yuko sustained were consistent with rape and the CCTV showed a "quite shocking" act of violence.
But defence barrister Barnaby Johnston argued there were was no DNA evidence linking Chalmers to those injuries, and Yuko had seen other clients in the lead-up to her death.
"It is utter guesswork how those injuries occurred," the defence barrister said.
He urged magistrate Vincenzo Caltabiano to discharge Chalmers of rape and the state offence of murder, which alleges the 36-year-old unintentionally caused the death during the rape.
Chalmers is also facing a separate charge of common law murder.
The prosecutor accepted it was an atypical and circumstantial case but argued it should be left to a jury to decide.
Mr Caltabiano will have to consider whether there is sufficient evidence to commit Chalmers to stand trial in the Supreme Court on all or some of the charges.
The magistrate adjourned his decision to March 31.
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