פירוש על ברכות 47:2

DIDN’T RABBI ḤIYYA TEACH [THAT] HE PLACES THEM IN A POUCH, UNDER HIS HEAD? R’ Yirmiyoh said that one places his t’filin between the mattress and the pillow not directly opposite his head. The Gemara challenges R’ Yirmiyoh from the Braiso of R’ Chiyo that says he places the t’filin in a pouch under his pillow. And if you ask: I can say that there is no contradiction from the Braiso to R’ Yirmiyoh because the Braiso is speaking of where the t’filin is in a pouch that is not directly opposite his head. I can prove that this is an acceptable answer to the Gemara’s challenge for in the Braiso quoted earlier (23b) it also says that t’filin can be placed under his pillow and the Gemara does not challenge R’ Yirmiyoh from that Braiso, because the Gemara is aware that we can explain that the Braiso is speaking of putting the t’filin not directly opposite his head. Why didn’t the Gemara seem to know that we can use the same answer in reference to R’ Chiyo’s Braiso?
And the Rav says: that if so, that R’ Chiyo’s Braiso is speaking of where the t’filin are not directly opposite his head why does he speak about placing them in a pouch, even without a pouch it should also be permitted to place t’filin not directly opposite his head. Rather we can see from this that it is speaking even where the t’filin are opposite his head. That is why this Braiso of R’ Chiyo contradicts R’ Yirmiyoh who says that one must place t’filin not directly opposite his head, whereas the previous Braiso that does not mention a pouch is not a contradiction to R’ Yirmiyoh.
However, in any case we remain with a problem, the Gemara should answer the challenge from R’ Chiyo’s Braiso by saying that the Braiso is speaking of when his wife is with him, where it is required that the t’filin be placed in a vessel within another vessel. That is why the Braiso speaks of a pouch even though it will be placed not directly opposite his head and it presents no contradiction to R’ Yirmiyoh at all. And the issue requires contemplation.