In the Colombian state access to justice tutelage action proceeds against a court ruling, however, neither the Constitution nor other laws explicitly establish such procedural action, so it has fallen to the Constitutional Court lucubrate on that figure. One method of origin of the writ of protection against default court order is factual, wich presupposes some probative issue in the judgment pronounced. This modality has been concretized by the Constitutional Court in several judgments, which are analyzed in this article from the perspective of legal arguments, and with special aim to the internal justification.