Depends on what kind of traffic these devices do. Having 10 smartphones won't require the same amount of bandwidth as having 5 computers all transferring large files. Those 10 smartphones will be fine with one single AP, while having 5 heavy users might benefit from spreading them between two APs.
Same if you have two low-speed 802.11n clients and two high speed 802.11ac clients - you might want to have two separate APs to separate these, so the N clients won't slow down your AC clients.
So there's no specific rule, it's situational.