There are two approaches which depend on the binding. If you have a "self cover" publication, you have the content – 32 pages in your example – all printed on the same stock (paper) and the cover would be page 1.
If you have a "separate" cover, that is a publication with a four page cover printed on a heavier stock and then bound with the inside section, the first page of the section would be page 1. The cover would not have folios but be printed, normally, on pages 1 and 4 (front and back cover).
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