Tse was giving evidence for the Crown against Simmonds' partner Samuel Pou, who is accused of killing her and burying her in a shallow grave on a property on Wilson Rd in Parakao sometime between February 23, 2019 and March 16, 2019.
It is alleged he punched Simmonds more than 100 times for over an hour after she spilled wine, leading to her death.
His nephew Te Koha Samuel Pou is also on trial on charges of dishonestly using Simmonds' bank card and helping his uncle avoid arrest.
Simmonds' body was found about 15 months after she was reported missing in early 2019.
Tse conducted the post mortem at the Auckland Hospital mortuary in June last year, and invited Auckland University biological anthropologist Professor Judith Littleton to assist due to the condition of the body.
There was more skeleton than body and Tse was uncertain of the fabric it was wrapped in.
Her body had fractures on the palm of her right hand, fibula, foot and near the knee, he said.
"The definitive cause of death can't be established because fractures itself are not absolutely fatal."
Police sought his advice over the phone on how best to remove Simmonds' body and said him not being present on-site did not disadvantage him.
Prior to Tse giving evidence, Detective Sergeant Paul Overton told the court of the painstaking manner in which he and other police officers removed dirt and uplifted what remained of Simmonds' body.
Overton said Tse advised him to remove the blanket that covered her body and put the remains in a body bag, while ESR scientists advised him against the blanket's removal as it could cause fragmentation of the bones.
In the end, he said a decision was made to remove the blanket.
Simmonds was lying on her left side, he said.
Overton said police made a tray out of aluminium sheet and slid it below the dirt before her body was gently lifted and transported to Auckland Hospital mortuary in June 2020.
The trial continues.
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