theory of the substitution of the which was adopted by our Constitutional Court, and included in the Colombian legal system, established the prohibition to the National Congress, of suppressing essential elements of the constitution when it is working on a reform of it. The reason is, according to the Court, that article 374 of the Constitution allows it s text to be reformed, not to be substituted. Therefore, if an essential element of the constitutional system is to be suppressed or substantially changed, the Court, in order to protect the constitution, must declare such reform as unconstitutional. But the constitution clearly states that a constitutional reform can only be declared as unconstitutional for reasons related to the procedure, not for its content, which is being done by the Court. Nevertheless, our Constitution allows the people, through a referendum, to derogate a constitutional reform when it includes the following topics: (i) fundamental rights and its means to protect them, (ii) the people s participation systems, (iii) the Congress. So basically, the Constitutional Court, in order to protect the Constitution, uses subjective judicial methods inspired by the fear of abuse of power that might result from unlimited constitutional reforms.