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In the 1912 U.S. Supreme Court case of Sy Joc Lieng v. Gregorio Sy Quia, the dispute revolved around an inheritance issue under Chinese law and its recognition in American courts. The petitioner, Sy Joc Lieng, claimed to be a legitimate son of a deceased Chinese merchant who had properties in Manila while living there with his concubine (Sy Joc Lieng's mother). On the other hand, Gregorio Sy Quia was recognized as a legal heir being born from lawful wedlock. According to Chinese customs and laws at that time, children born out of wedlock could inherit their father's property equally with those born within marriage if they were acknowledged by their father during his lifetime. The court ruled against recognizing such provisions of foreign law when it contradicts public policy or moral standards prevalent in American society where legitimacy is strictly determined by marital birth. Therefore, despite acknowledging him as a son according to traditional Chinese customs and laws applicable then in China itself or among overseas communities elsewhere globally including Philippines (then under US jurisdiction), he wasn't considered eligible for inheritance rights equal to those enjoyed by offspring from legally married parents under prevailing local norms governing family relations & succession matters across United States territories.
In the dissenting opinion for SY JOC LIENG v. GREGORIO SY QUIA, it was argued that the court should not have interfered with a Chinese custom of adopting children without legal formalities. The justice believed that this case did not involve any violation of public policy or morals and thus, there was no reason to deny recognition to such adoptions in probate proceedings. He asserted that these informal adoptions were widely recognized and respected within the Chinese community, which constituted a significant portion of the population at that time. Therefore, he felt it would be unjust to disregard their customs simply because they differed from Western practices.