Jude 9 says:
"But when Mi´cha·el the archangel had a difference with the Devil and was disputing about Moses’ body, he did not dare to bring a judgment against him in abusive terms, but said: “May Jehovah rebuke you.”'
Because Jude 9 says that "he did not dare to bring a judgment against him in abusive terms but said: “May Jehovah rebuke you”, shows that Michael COULD have rebuked Satan but humbly left the judgement up to God at that time.
Also, the Bible clearly shows that Michael has prevailed over Satan:
"And war broke out in heaven: Mi´cha·el and his angels battled with the dragon, and the dragon and its angels battled but it did not prevail, neither was a place found for them any longer in heaven. So down the great dragon was hurled, the original serpent, the one called Devil and Satan, who is misleading the entire inhabited earth; he was hurled down to the earth, and his angels were hurled down with him." (Rev. 12:7-9)