Honestly, I'd say it's up to you to decide which one you like better. If you plan on using a newer system (like a Pentium III or 4) for 98SE, I'd use 95, otherwise, I'd use 98.
You can use this example on how I have my two 9x rigs managed, sure I could run Windows 98 on my Celeron-433 rig, but since I have a Pentium III rig for 98, I'm using Windows 95OSR2 on that build. There's no reason to induce OS redundancy by using the same OS on two rigs when I can use an older, but still compatible OS on the older rig.
The advantage of going with 95 on your P1 build is it's lighter on resources so it should run smoother with the 32MB of RAM that you have (I hear that 64MB is the soft spot for 98), but 98 does have the advantage of being compatible with newer (~2001-2007) software although there might not be a lot of 98-exclusive programs that'll run smoothly on your system.