That's kind of how I work, even if it does not necessarily look like it on the finished pages.
I spent a lot of time when I was younger, creating illustrations with tissue paper and glassine for the background, and construction paper for foreground, and that's still how I (in my mind) work with digital comics. I'm going away from it though because I did not find a solution to make it look like I wanted. So I'm not the good person for giving advice, but I'm sure it's possible, and I find it a very interesting approach.