One duplex or two single receptacles can have enough load plugged in to trip a breaker, so there's no quantity that magically prevents the possibility.
One could have a commercial building with 50 hallway receptacles that will only be used for vacuum cleaning, and could function fine on a single circuit.
On the other hand, a single residential kitchen duplex receptacle could be overloaded with a toaster oven and a coffee maker or microwave oven.
Even those here who believe that Art. 220 calculations also apply to actual design and installations must admit that any limit is really arbitrary.
Every circuit should be designed according to actual use, and not to rules of thumb that have no basis in fact. A 13-receptacle limit is no guarantee.