Chamilo might use more than 32MB to load some specific pages (in particular reporting pages or scripts never loaded before). On average it will use only about 22MB per page for version 1.10, for example.
The error message you are seeing specifically indicates that there is still an active 32MB memory limit.
If you already changed it in php.ini, it is likely (on a cPanel install) that some .htaccess file will override this limit and set it back to 32MB. Depending on where your Chamilo root directory is located, this .htaccess file might be, for example, in /public_html/.htaccess if your Chamilo directory is in /public_html/chamilo/. (.htaccess files do modify the settings for all directories under their location).
.htaccess limits should look like this:
php_flag memory_limit 32M
Alternatively, something above your cPanel (WHM is a frequent companion to cPanel) might prevent cPanel to actually set the memory_limit. You might have access to the platform controlling your cPanel or not. If not, you should contact your hosting provider and ask them to put that limit higher.
If you manage thousands of students, the memory consumption might go as high as 256MB for some reports, so ask them directly to change that limit to that.
If you are using a development version of Chamilo, memory consumption might go much higher because of the use of memory-hungry Symfony components.