With assembly processes which are sequentially manually layered up, one naturally needs to have the most opaque color at the bottom and the most transparent on top. Sometimes this has an odd effect where a physical relief is apparent, as in color carbon prints, where normally receding pigment hues end up on top, but the warm hues sink in the recesses, due to the gelatin sandwich being flipped onto a final substrate.
But these kinds of prints are made from separation negatives and tricolor additive filters. This all would be meaningless in a filter drawer containing subtractive filters for ordinary color papers.