The Constitutional Court of Colombia, over the last ten years built a dogmatic theory competency limits the power of reform that would allow control the content of the reforms made to the 1991 Constitution. However, although it seems that this thesis-she says she is an unfinished theory-was built on solid theoretical basis, the fact is that it can be subject to strong criticism. Among them, and that the complaint in the present paper, is that there is consistency from the theory of judicial discretion.