In his commentary on Jude 9, Bede seems to be open to the belief that “the body of Moses” is not about the singular person of Moses, but a corporate entity (i.e., the children of Israel):
9 When Michael the
archangel quarreled with the devil and contended over the body of Moses, he did
not dare to bring a judgment of blasphemy but said, ‘May God order you.’ It is not entirely
obvious from what scriptures Jude took this witness. But nonetheless we should
know that we find something like it in the prophet Zechariah. For indeed he
says that, The Lord showed me Jesus the
priest standing before the angel of the Lord, and satan was standing at his
right hand, that he might oppose him. And the Lord said to satan, ‘May the Lord
rebuke you, satan, and may the Lord who chose Jerusalem rebuke you.’ But in
this place it is very easily understood that Jesus the priest desired that the
people of Israel be freed from the captivity of Babylon and return to their
fatherland, but satan resisted him, unwilling for the people of God to be
freed, but instead sold to the enemy, and these gentiles, and therefore the
angel who was the peoples’ helper, rebuked him and removed him from doing
further injury to the same people, But we remain uncertain when Michael had a
struggle with the devil over the body of Moses. But nevertheless there is no
lack of those who say that the same people of God have been called the body of
Moses from the fact that Moses himself was part of that people, and therefore
that Jude was properly able to say that what he had read had been done to the
people had been done to the body of Moses. But wherever and whenever this
contention of the angel with the devil occurred, we must carefully consider
that if Michael the archangel was unwilling to bring a charge of blasphemy
against the devil who opposed him, but restrained him with a mild word, how
much more ought all blasphemy be avoided by human beings, and especially lest
they offend by a careless word the majesty of the Creator. (Saint
Bede the Venerable, The Commentary on the Seven Catholic Epistles of Bede the
Venerable [trans. David Hurst; vol. No. 82; Cistercian Studies Series 82;
Kalamazoo, Mich.: Cistercian Publications, 1985], 244–245)