Carlos Eduardo Valdes told Colombia Reports homicide was the primary cause of death followed by accident and suicide.
Of the 105 cases, Valdes said 36 were classified as homicides, 13 as suicides and 17 as the result of transit accidents.
The remaining deaths are still under investigation, he said.
Valdes said the numbers translate to five dead children per day during the first three weeks of January.
Reindeer recovered after escaping from Santa during lighting ceremony
Selena Gomez drops F-bomb, walks off stage during Jingle Ball performance