I have successfully used 64GB cards in many devices that stated "up to 32GB".. some take the 64GB card right out of the box, others need reformatting. Some have formatted the 64GB sd card to FAT32 file system because the device doesn't support the cards native exFAT format.
There are no guarantees that it will work, but yes it is entirely possible even if the phone says "up to 32GB"